NAVIGATING THE TAX LANDSCAPE: CLARIFYING TRANSFER DUTY V VAT ON THE SALE OF SHARES IN A PROPERTY-OWNING COMPANY CONNECTED TO AN ENTERPRISE
By Abduraghmaan Farao
In a property-related transaction, one is responsible for paying transfer duty or VAT. There is no division or apportionment of these payments, which are regulated under two separate Acts.
Under the Transfer Duty Act 40 of 1949 (‘TD Act’), the purchase of shares in a company is subject to transfer duty if the company is a residential property company. As defined in section 1(1)(b) of the TD Act, a ‘residential property company’ is a company that holds residential property where the fair value of the property comprises more than 50% of the aggregate fair value of all assets held by said company. Under the same Act, a ‘residential property’ includes any dwelling-house, apartment, and holiday home, but excludes a hotel, guesthouse, and apartment complex of five or more units used for rental purposes.