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Income tax: is the amount received from the sale of vendor shares by a bona fide prospector, who received the shares as consideration for the sale of mining tenements, exempt in terms of paragraph 23(pa) or subsection 160L(7) of the Income Tax Assessment Act 1936 ?

Preamble

No. The provisions of paragraph 23(pa) or subsection 160L(7) do not apply to exempt the profit from the sale of vendor shares by the prospector.

Exemption under paragraph 23(pa) or sub section 160L(7) does apply in the case of income derived by a bona fide prospector from the sale, transfer or assignment of his or her rights to mine gold or any prescribed metal or mineral.

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