South Africa: the Volkswagen case and the secondary tax on companies : Part 1 - the outcome

In Part 1 of this article, the author examines the recent South African High Court case of Volkswagen regarding the secondary tax on companies and, in Part 2, considers the implications of the case for the taxation of dividends in the country and, more generally, deals with the OECD Model Tax Convention's dividend definition as applied to deemed (constructive) dividends.