Tag: Income Tax Act (page 1 of 3)

Tax liability in financial emigration

Section 9H of the Income Tax Act deals with matters relating to the cessation of residency in South Africa.

This section essentially states that where a person that is a resident ceases to be a resident during any year of assessment, that person must be treated as having disposed of his assets on the date immediately prior to ceasing his residency, and re-acquiring the same assets on a date immediately thereafter. This is referred to as a “deemed disposal”. Similarly, the year of assessment will be deemed to have ended immediately prior to the cessation and to have started on the next day.

Such a “deemed disposal” does not relate to the immovable property that such a person may hold in South Africa.

As a result of his ceasing to be a South African tax resident (an event simply declared by ticking a box on the annual income tax return when submitted), a so-called “deemed disposal” (also sometimes referred to as an “exit charge”) will be activated in terms whereof all the individual’s assets will be deemed to have been disposed of, at market value, on the day before he ceased to be a South African tax resident.

This event, therefore, potentially gives rise to capital gains tax incurred on the deemed disposal. Excluded from this regime, as stated above, is South African immovable property, cash and (although not explicitly stated, though included on a very technical basis) accumulated retirement-related funds. Apart from these assets, all remaining South African and other worldwide assets are included in the “deemed disposal” regime.

Before a taxpayer decides on cessation of tax residency, an investigation should be done into possible tax treaty relief the individual may qualify for. SARS has stated that “an individual who is deemed to be exclusively a resident of another country for purposes of a tax treaty is excluded from the definition of “resident”. It follows that while an individual may qualify as a resident under the ordinarily resident or physical presence tests, that individual will not be regarded as a resident for South African tax purposes if that person is a resident of another country when applying for a tax treaty.”

Based on this, it is clear that section 9H of the Income Tax Act immediately becomes applicable to a taxpayer in the case of financial emigration or the cessation of tax residency, for whatever reason, and may increase tax liability in the current year of assessment in which the cessation of residency occurs. One must, however, always remember the exemptions described above, and in the event that emigration and/or ceasing to be a tax resident is considered, pre-emigration planning is of utmost importance to ensure that a smooth and fluid transition plan is formulated.

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

Section 7C of the Income Tax Act explained

What is section 7C?

This section of the Income Tax Act is an anti-avoidance measure aimed at transactions between connected persons and trusts, where a trust is funded by low interest or interest-free loans. This is usually done to ensure that assets form part of the trust’s capital, and the funder (who is usually a trustee or founder of the trust) allows for the transfer of ownership of the assets, and the creation of a loan account in said person’s favour.

The sections allow for any loan, advance or credit by a connected person, directly or indirectly to a trust, and this loan, advance or credit incurs no interest, on the loan, advance or credit, or incurs interest at a rate lower than the official rate, an amount equal to the difference between the amount of interest incurred, and the amount it would have incurred had an acceptable interest rate (official rate)  been used, will be deemed as a donation in the hands of the lender. For purposes of this section, the same principle applies where a company who is owned by trust loans on terms that are not regarded as commercial or market-related and no interest is charged.

What is the reasoning behind section 7C?

Trusts have traditionally been a very popular estate planning tool. In the past, the practice was to sell growth assets to a trust and to then extend an interest-free loan to the trust for that sale price. That would mean that the estate of the seller would be pegged at that value because the loan would not increase in value as time goes by while the assets would grow in the trust. Section 7C seeks to address this practice, as it is argued such a transaction should be seen as having no commercial sense, as only the trust benefits. The seller earns no interest on the loan and hence derives no value or benefit.

How does section 7C work?

Section 7C deems the interest that is not levied or charged on an interest-free loan, as a deemed donation on the last day of each tax year for a loan that was outstanding for any period during that preceding tax year.

The interest forgone is calculated by using the official interest rate in the 7th Schedule to the Income Tax Act, currently being 7.25%. This would be regarded as a deemed donation on the last day of the tax year and as a consequence donations tax would be levied on that donation.

Where there is a low interest-bearing agreement, the difference of the official interest rate and the lower interest rate will determine the deemed donation.

Trusts and loan accounts

Should I be charging interest on a loan, advance or credit to a Trust?

Making section 7C practical will require the use of a few examples to illustrate its effect.

Example 1

A loan in the amount of R10 million is advanced by an individual to a trust with no interest charged by the lender. The individual will choose to apply his annual donations tax exemption of R100,000.00 to the deemed donation.

The deemed donation will be R725,000 (R10 million x 7.25%). The individual then applies his annual exemption of R100,000.

The donations tax liability will be calculated as follows: R625,000 x 20% = R125,000 which the individual will be required to pay.

Example 2

A loan in the amount of R10 million is advanced by an individual to a trust with an annual interest charge of 5% by the lender. For this example, we will ignore the lenders annual donations tax exemption.

The deemed donation will be calculated as follows: R10 million less x 2.25% (the difference between interest levied and the official rate or 7.25% – 5%). The deemed donation will be R225,000.

The actual donations tax liability is then R225,000 x 20% = R55,000. The lender may now apply his annual R100,000 donations tax exemption.

It is clear that the non-charging of interest, or charging at a lower rate, may result in an increase in personal tax liability for the lender.

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

Are my donations being taxed?

BPR 338 deals with the tax treatment of payments made to a Public Benefit Organisation (PBO) at a fundraising event, under section 30 of the Income Tax Act. The ruling is essentially an interpretation of section 18A of the Act and seeks to clarify the situation for PBOs and funders.

In terms of the transaction, the Applicant (a resident company registered as a PBO) will host an event for the explicit purpose of fundraising, but this event will be managed by a third-party events management company.

As is commonplace, persons attending the events will make payments to participate in activities taking place at the event, as well as make donations. The events management company manages an electronic system that will enable funders and donors to make payments at the event. This system is accessible through various roaming electronic touchscreen devices, developed for the distinct purpose of distinguishing between donations and payments for activities.

By the end of the evening, each attendee is required to settle their required payments in respect of the relevant transactions they entered into, with one single card payment. The system then determines which attendee is entitled to a section 18A certificate, as well as the amount to be reflected on the receipt. Only donations made by attendees are reflected on the section 18A receipt.

One condition and assumption of this ruling is that the payment tracking system must, as closely as practicable, conform to the one proposed and its intended function, accounting for the donations of money separately from payments, must be easily verifiable.

The ruling made by SARS is that donations made and identified as such by the applicant’s payment tracking system at the fundraising event will constitute bona fide donations made to a PBO under section 18A of the Act, and as such, the applicant may issue the donors with section 18A receipts in respect thereof.

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

What happens during liquidation?

The South African Revenue Service (“SARS”) issued Binding Private Ruling 336 on 6 December 2019.

In terms of this ruling, a listed resident company (“the Company”) previously granted a loan to its wholly-owned resident subsidiary (“the Subsidiary”) in order for the Subsidiary to acquire shares in the Company. The Company subsequently decided to deregister the Subsidiary.

In order to affect the deregistration, the Subsidiary proposed to, in anticipation of its deregistration, distribute all its assets (the Company shares) to the Company as a dividend in specie and as a liquidation distribution as contemplated in section 47 of the Income Tax Act.[1]  In return, the Company will waive the outstanding loan and cancel the Company shares so distributed by the Subsidiary to the Company. The Subsidiary will then be deregistered.

SARS confirmed in the ruling that no adverse tax consequences should arise for either the Company or the Subsidiary based on the following reasons.

SARS agreed that the distribution of the Company shares by the Subsidiary will constitute a liquidation distribution as contemplated in section 47.[2]The distribution will therefore not result in any capital gains tax consequences for either the Company or the Subsidiary. The Company should furthermore disregard the disposal or any return of capital for purposes of determining its taxable income, assessed loss or aggregate capital gain or aggregate capital losses.[3]

The liquidation distribution constitutes a dividend and must be included in the Company’s gross income. However, SARS confirmed that the dividend will be exempt from income tax in terms of section 10(1)(k)(i). The dividend will also not be subject to dividends tax (section 64G(2)(b)).

No securities transfer tax will arise on the transfer of the shares from the Subsidiary to the Company (section 8(1)(a)(v) of the Securities Transfer Tax Act[4]) and the subsequent cancellation of the shares so received by the Company will not constitute a disposal (paragraph 11(2)(b)(i) of the Eighth Schedule to the Income Tax Act).

The ruling furthermore confirms that paragraph 77 (relating to distributions in liquidation or deregistration received by holders of shares) and paragraph 43A (dividends treated as proceeds on disposal of certain shares) of the Eighth Schedule will also not apply to the proposed transactions.

There will also not be any capital gains tax consequences with regards to the loan waiver as the reduction of debt between connected persons in anticipation of deregistration is specifically excluded in paragraph 12A(6)(e) of the Eighth Schedule.

SARS granted the ruling subject to an additional condition, that is to say, that the Subsidiary takes the required steps to deregister within a period of three years as contemplated in section 41(4).

  • [1] No. 58 of 1962
  • [2] See the definition in paragraph (a) of section 47(1).
  • [3] Section 47(5)
  • [4] No. 25 of 2007

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

Audit certificates: What you need to know?

The South African Revenue Service (“SARS”) issued Interpretation Note 112 on 21 June 2019 to provide guidance on the interpretation and application of the audit certificate requirement as set out in section 18A of the Income Tax Act.[1]

For background purposes – section 18A provides a taxpayer with an income tax deduction for bona fide donations paid to certain approved organisations such as qualifying public benefit organisations (“PBOs”) and other approved agencies, programmes, funds, the High Commissioner, offices, entities or departments.

The requirements needed to qualify as a PBO are set out in section 30 of the Income Tax Act. Part I of the Ninth Schedule to the Income Tax Act lists a variety of activities that are considered to be public benefit activities (“PBAs”) for purposes of section 30. Only certain of these PBAs will result in the approved organisation qualifying for section 18A status. These activities are listed in Part II of the Ninth Schedule.

In terms of section 18A(2A), these approved organisations may only issue section 18A receipts to the extent that the donation received or accrued during the year of assessment will be used to carry on PBAs as set out in Part II of the Ninth Schedule.[2] For conduit PBOs (i.e. PBOs set up to provide funding or assets to other PBOs), 50% of the donations must be distributed within 12 months and the funds must be used by the second PBO to carry on Part II PBAs.[3]

Approved organisations are allowed to conduct a combination of Part I and Part II activities. In order to ensure that section 18A receipts are issued only in respect of donations that would be, and ultimately are, used for purposes of Part II PBAs, approved organisations are required to obtain and retain an audit certificate.[4] This is seen as a reasonable requirement given the fact that the person making the donation could claim a tax deduction if issued with a section 18A receipt and the approved organisation receiving the donation is exempt from income tax.

To date, section 18A did not include detailed requirements with regards to the audit certificate. Examples include the information that must be contained in the audit certificate and from whom the audit certificate should be obtained in certain instances. As a result, uncertainty exists on how to comply with the audit certificate requirements. Interpretation Note 112 was therefore issued to provide guidance in this regard.

Approved organisations should therefore carefully consider Interpretation Note 112 to ensure that the audit certificate meets all the relevant content requirements, is obtained from the correct body or authority and is timeously submitted to SARS.

[1] No. 58 of 1962

[2] Section 18A(2A)(a)

[3] Section 18A(2A)(b)

[4] Section 18A(2B)

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

TAX IMPLICATIONS OF THE VARIATION OF EMPLOYMENT CONTRACTS

On 6 November 2018, the South African Revenue Service (“SARS”) issued a binding private ruling (“BPR 312”) in accordance with sections 78(1) and 87(2) of the Tax Administration Act.[1] This ruling set out the tax implications of varying employment contracts.

Here the applicant (a resident company) previously entered a profit share arrangement with Mr X, who was entitled to nominate certain employees (of two 100% held subsidiaries of the applicant) to also benefit from this arrangement. The parties subsequently entered into a cancellation agreement to terminate the profit share arrangement and to allow for certain payments to be made by the subsidiaries to the nominee employees.

Although the payments (and the subsequent tax implications thereof in terms of the Income Tax Act[2]) seems standard for this type of agreement, the ruling neatly confirms these implications of each of these payments for both the subsidiaries and the employees.

Firstly, the subsidiaries would pay a pre-determined cancellation fee to the affected employees as compensation for cancelling the profit share arrangement, including payments to other employees pursuant to the cancellation agreement even though they were not applicants to the ruling or parties to the cancellation agreement. The ruling confirmed that both these payments were deductible for income tax purposes under the general deduction formula.[3]

Secondly, a cash portion was retained by the applicant to be released to Mr X in August 2021. This amount was treated as security for Mr X to comply with certain obligations he had in terms of these agreements. The cash portion will be forfeited if Mr X is dismissed prior to the date of release.

SARS confirmed that the cash portion was a pre-payment subject to section 23H in the hands of the applicant.  Also, that both the cancellation fee and the retained cash portion should be included in the employees’ gross income.[4] Mr X will, however, qualify for a tax deduction should the amount be forfeited in terms of section 11(nA), which allows for a deduction of any voluntary award received by virtue of employment that was included in taxable income but is subsequently refunded.

Lastly, the cancellation agreement made provision for agreements that allowed for restraint of trade payments to be made to certain employees. The subsidiaries could deduct these amounts in terms of section 11(cA) while these payments were to be included in their gross income in terms of paragraph (cB) of the definition of “gross income” in section 1.

[1] No. 28 of 2011.

[2] No. 58 of 1962. Any subsequent references to “sections” are to the sections of this Act.

[3] Section 11(a) read with section 23(g).

[4] Paragraph (d) of the definition of “gross income” in section 1 which specifically allow for a payment as a result of a variation of employment.

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

Additional changes to income tax returns for trusts

The South African Revenue Service (“SARS”) implemented several changes to the income tax returns for trusts (the ITR12T) on 17 September 2018. These changes are in addition to the changes already made on 26 February 2018. The September 2018 changes apply in respect of the year of assessment ending on 28 February 2018. Taxpayers that already saved or submitted the relevant 2018 ITR12T prior to the implementation of the latest changes, will not be presented with any of the new fields for completion.

Similar to the February 2018 changes, these additional changes form part of SARS’ ongoing efforts to promote efficiency and compliance.

Three new fields will be pre-populated on the ITR12T. The first is the “Trust Type”. Validation questions will be presented for a response if the Trust Type is Special Trust Type A or B. The Trust Type may change based on the answers provided.

The second and third fields relate to income from local farming operations (IT48) and income from local partnership farming operations (IT48V). These fields will now include auto-calculations and cater for negative currency to be captured.

Where applicable, trustees will now also be able to select one or both of the following options: “vested” and “discretionary”.

The ITR12T wizard has also been updated to include a question pertaining to imputed income from controlled foreign companies (“CFC”). If this question is answered yes, the ITR12T will display a new container to be completed. Please note that trusts, together with any connected person in relation to the trust, that holds at least 10% of the participation rights in a CFC, will also be required to submit a completed IT10B form (or IT10A form for years prior to 2012).

More fields have been added to the ITR12T with regards to the reduction of debts (section 19 of the Income Tax Act[1]), cash contributions to a rehabilitation trust fund (section 37A of the Income Tax Act) and amounts in respect of certain (tainted) intellectual property (section 23I of the Income Tax Act).

Furthermore, SARS indicated that the following documents should be submitted with the ITR12T (as a minimum) and include financial statements and/or administration accounts, all certificates and documents relating to income and deductions, proof of any tax credits claimed, particulars of assets and liabilities, as well as details of persons or beneficiaries to whom income, capital and/or assets were distributed or vested.

The take away is that trusts should carefully consider these new requirements in order to ensure that the relevant ITR12T is completed correctly. For more information on these new fields, an example of the new ITR12T form is available on SARS’ website for consideration.

[1] No. 58 of 1962

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

Deduction for photovoltaic solar energy plants

Section 12B(1) and (2) of the Income Tax Act[1] provides for a 50/30/20 income tax deduction in respect of certain machinery or plant owned by the taxpayer and which was or is brought into use for the first time by that taxpayer, for the purpose of his or her trade to be used by that taxpayer in the generation of electricity from, amongst others, photovoltaic solar energy (both for energy of more than 1 megawatt and energy not exceeding 1 megawatt) or concentrated solar energy. The tax deduction also applies to any improvements to the qualifying plant or machinery which is not repairs.

In cases of plant and machinery used in the generation of electricity from photovoltaic solar energy in respect of energy less than 1 megawatt, the taxpayer may write off 100% of the costs of such plant or machinery in the year brought into use.[2]

The cost of any asset for purposes of section 12B also includes the direct cost of installation or the erection thereof.[3]

In a recent binding private ruling (BPR 311) the applicant proposed to install solar power systems at each of the sites it rented to reduce electricity costs. As each system will only be supplemented and not replace the electricity provided by the main grid, it was proposed to generate less than 1 megawatt of electricity.

The taxpayer will purchase the photovoltaic solar panels, appoint and pay independent contracts to perform the installation planning, procure and purchase all other relevant equipment and install the systems at the relevant sites. These systems at each site comprised of the panels, AC inverters, DC combiner boxes, racking, cables and wiring.

In terms of the ruling, the taxpayer was entitled to claim the costs in respect of all the components of each system in terms of sections 12B(1) and (2). As each system will generate less than 1 megawatt of electricity, 100% of these costs were deductible in the year brought into use. No deduction was, however, claimed in respect of the costs of distribution boxes as it did not form part of the photovoltaic solar energy system.

It was furthermore proposed that the taxpayer would incur certain related expenditure as part of the cost of the installation, including the installation planning costs, panel delivery costs and installation safety officer costs. SARS, in this regard, ruled that these costs all formed part of the direct costs of installation and erection of the systems and were therefore deductible in terms of section 12B(3).

Taxpayers installing solar energy systems should therefore carefully consider the tax deductions in terms of section 12B to ensure that all relevant costs are claimed for income tax purposes.

[1] No. 58 of 1962

[2] See section 12B(2)(b)

[3] Section 12B(3)

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

DEBT REDUCTION RULES: NEW TAXPAYER FRIENDLY AMENDMENTS EXPECTED

The South African Income Tax Act contains a number of rules which give rise to onerous tax consequences where a taxpayer’s debts owing is forgiven. These rules were in recent years the subject of comprehensive legislative amendments.

During the 2018 budget process, National Treasury indicated that it was aware of unintended tax consequences that arise from these new debt relief rules in the Income Tax Act that became effective for years of assessment beginning on or after 1 January 2018. On 31 May 2018, the South African Institute of Chartered Accountants (SAICA) published a feedback summary report from a recent National Treasury workshop to consider proposals for amendments to these rules.

The proposal from that workshop is that the scope of the debt forgiveness rules will be changed through an amendment to the definition of the term ‘concession or compromise’ to focus on rationalisation events. A number of transactions that were previously subject to the onerous rules will from now on fall outside of its scope in future, such as where changes to the terms and conditions of a debt are made only.

One of the most significant proposed changes is the degree to which the conversion of debts to shares (debt capitalisation) are subject to the debt forgiveness rules. Currently, capitalisation of all debts is subject to the rules. A new definition for ‘interest-bearing debt’ will be introduced, to make only interest-bearing debt that is capitalised subject to the rules. This proposal is commercially friendly and provides taxpayer-companies in distress with more options for debt restructures without the fear of triggering adverse tax consequences in the process. Group companies will also have the benefit of its interest-bearing debt excluded from the rules; however, interest thereon may be recouped on capitalisation.

Very significantly, changes will be made to the valuation requirements of the debt forgiveness rules. It will no longer be required to consider the valuation of debt, only that of the shares issued in consideration. Determining the value of debt is currently one of the more contentious matters in the debt reduction regime, given that there are often constraints in obtaining an objective valuation for debt if it is not traded publically. This is a welcome proposal. The concepts of ‘market value’ and ‘face value’ which are used to determine whether any debt benefit arises because of a forgiveness of debt will also be clarified.

National Treasury also indicated that it will provide clarity on certain anti-avoidance matters relating to debt forgiveness, as well as indicating that the donations tax exclusion currently in place, will be removed.

Although feedback from the workshop is at a high level, initial indications are that many of the uncertainties and unintended consequences in the debt forgiveness rules will be addressed when the draft Taxation Laws Amendment Bill is published early in July 2018. No invitation has been made for public comment on the proposals, since this will be dealt with during the 2018 legislative amendment cycle. The effective date of the proposals will be 1 January 2018.

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

EMPLOYEES’ TAX (PART I): PERSONAL SERVICE PROVIDERS

For there to be an obligation for PAYE to be withheld is typically dependent on three elements being present. These elements are all defined in the Fourth Schedule to the Income Tax Act[1] and include the presence of an employer, an employee and the payment of remuneration. No employees’ tax can be charged if one of these elements is absent.

As a result of certain avoidance structures being implemented to avoid employees’ tax, specific tax provisions were introduced dealing with “personal service providers” (or “PSPs”) to combat such possible instances of tax avoidance and to limit the available deductions from income in the determination of taxable income for these entities.[2] What individual taxpayers would do to limit their effective tax rate (and to ensure that PAYE is not withheld from remuneration paid to them) otherwise would be to earn their salaries in entities controlled by them. In other words, an employee would arrange with his/her employer that a company owned by the employee would rather be rendering the same services as an employee to the employer. This company would then earn remuneration, even though it would be performing exactly the same services as the employee otherwise would have and had that individual not rendered those services through that company.

It was therefore necessary to include a PSP in the definition of “employee” for tax purposes. A PSP can be a company, close corporation or trust, where any service rendered on behalf of the entity to its client (the would-be employer) is rendered personally by any person who stands in a connected person relationship to such entity. One of three additional requirements must be met for an entity to be a PSP:

  • The client would have regarded the person as an employee if the service was not rendered through the entity.
  • Alternatively, the person must render the service mainly at the premise of the client and he/she is subject to control and supervision of that client as to the manner in which the duties are performed.
  • More than 80% of the income derived from services rendered by the company is received from one client.[3]

A PSP is deemed to be an “employee”[4] and any remuneration[5] received by the PSP is subject to the withholding of employees’ tax in the form of PAYE too. Income tax deductions for PSPs are themselves also severely limited, typically akin to what would have been the case for individual employees themselves. It is recommended that clients of potential PSPs should have policies and systems in place to correctly identify and withhold tax from these entities.

[1] No. 58 of 1962.

[2] Also see SARS Interpretation Note 35 (Issue 4) dated 28 March 2018.

[3] Also includes any associated person in relation to the client.

[4] See the definition of “employee” in paragraph 1 of the Fourth Schedule to the Income Tax Act.

[5] See the definition in paragraph 1 of the Fourth Schedule to the Income Tax Act.

[1] L Taxpayer vs The Commissioner for the South African Revenue Service (Case A124/2017, on appeal from the Tax Court).

This article is a general information sheet and should not be used or relied upon as professional advice. No liability can be accepted for any errors or omissions nor for any loss or damage arising from reliance upon any information herein. Always contact your financial adviser for specific and detailed advice.  Errors and omissions excepted (E&OE)

Older posts

© 2022 T Roos

Theme by Anders NorenUp ↑