The alluvial diamond industry : a critical analysis of the capital cost allowances
Bibliographic record
Abstract
The purpose of the study was to critically analyse sections 15 and 36 of the South African Income Tax Act which deals with capital allowances for mining taxpayers from an alluvial diamond miners’ perspective. The South African analysis was also compared to that of Canada and Namibia. In the analysis it was found that the ring fencing provisos in section 36 is unfair towards the alluvial diamond mine due to the potential loss of capital cost allowances and that there are grey areas in this proviso that may lead to disputes between SARS and the taxpayer. It was also found that the cross over from prospecting to mining activities in relation to alluvial diamond mining presents a grey area which might lead to disputes between the tax payer and SARS. It was also found that there is no case law, SARS interpretation notes or practise notes on the application of these sections to provide certainty as to the tax payers’ position. It was recommended that SARS and treasury evaluate and address the identified grey areas and short comings in the current legislation and practises to ensure a fair and equitable tax dispensation for the alluvial diamond miners. Copyright
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.009 | 0.024 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.006 | 0.004 |
| Science and technology studies | 0.003 | 0.005 |
| Scholarly communication | 0.007 | 0.004 |
| Open science | 0.001 | 0.002 |
| Research integrity | 0.001 | 0.003 |
| Insufficient payload (model declined to judge) | 0.004 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".