I have been involved in the Insurance Industry, specifically the Income Tax side thereof, since 1997.

At that time, I had just passed my QE and wasn’t too sure where I was headed.

I applied for a contract position at the SARS LBC (Large Business Centre), which was called the CTC (Corporate Tax Centre) at the time, and I worked there, on a contract basis, for seven years.

At that time the focus of the CTC was Income Tax only.

During my time at SARS, I was introduced to some of the SARS processes and thoughts behind those processes. I also learnt a fair amount about the Insurance Industry - both long-and short-term.

When I joined SARS, I was under the impression that I knew something about tax, but when I was introduced to insurance and saw terms such as UPP, URR, IBNR, OCR and the like, I realised that I had barely scratched the surface.

And so, the journey began.

I initially got involved in the short-term Industry, and a few months later I was also introduced to the intricacies of the taxation of long-term insurance companies. I have been involved in this part of the industry ever since.

Many things have changed since I first became involved, but there are also some foundational principles that have remained broadly the same.

If one does not understand the background and certain foundational concepts, it is often very complicated to understand the inner workings of section 29A and 29B of the Income Tax Act (the Act), which are the sections that deal with the taxation of long-term Insurers.

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