compass JUNE 2014 ISSUE TWENTY SEVEN Learning and Development holds strategic benefit Business Rescue: A viable solution Setting achievable financial goals Cybersecurity is BIG business Implications for Real Estate Investment Trusts (REITS) IFRS 10: To consolidate or not to consolidate…? Kimberley consolidates Mazars’ Northern Cape footprint registered auditor – a firm of chartered accountants(sa) AUDIT • TAX • ADVISORY LEARNING AND DEVELOPMENT HOLDS STRATEGIC BENEFIT The key challenges faced by Learning and Development professionals today are in the strategic domain and yet the real value of Learning and Development departments lie in their strategic contribution to business. David Ulrih and Wayne Brockbank from the University of Michigan found that where Human Resource (HR) and Learning professionals understand their business and make strategic contributions, business can show up to a 250% increase in business performance compared to companies with a more transactional focus. Perspectives Conference 2014 and, the Mazars brand was recognise as a growing learning organisation setting trends in a global learning domain. We look forward to leveraging the global contacts to share best and next practice in the learning world to further enhance our competitive advantage as an employee developer of choice. “A game-changing impact on business performance can be achieved when talent development has a strategic view.” (Effective Learning with 70:20:10, Charles Jennings and Jerome Wargnier) It was with this focus in mind that Mazars National Learning and Development team developed the award winning THRIVE – Executive Thought Leadership programme aimed at the Mazars South African Board. This case study was presented at the Global Skillsoft Perspective Conference in Las Vegas in April this year by Judy Robison, Director of Mazars Learning and Development. The programme was piloted as a blended learning opportunity to drive thought leadership and strategic conversations contributing to organisational sustainable growth, improved productivity and transformation for the executive leadership team. The THRIVE programme’s design and, its ability to cascade throughout linked leadership and management programmes, won the recognition of a strategic learning intervention and enabled the international case study presentation, where it was very well received. Many wonderful networking opportunities were created at the Skillsoft 2 MAZARS New blended learning programmes underway, under development or ready for launch in 2014 include Professional Practice Management, Administration Professional, Ignite Accelerated Development and Audit Trainee IT and Pervasive Skills programmes. Should you have any queries about the THRIVE programme or the custom design of learning programmes for your work environment please contact Judy Robison. JUDY ROBISON Director: Mazars Academy [email protected] BUSINESS RESCUE: A VIABLE SOLUTION Business Rescue proceedings were introduced to South Africa as an alternative to liquidation on 1 May 2011 and, since then the process has developed significantly to a point where it is being accepted by leading institutions as a viable and cost effective method of finding the best solution for a business considered to be ailing and/or failing. The latest South African Companies and Intellectual Property Commission (CIPC) statistics reveal that from 1 May 2011, 1526 companies initiated Business Rescue proceedings as a way to save, salvage or resurrect the business. These figures include legal applications made in court. Since inception there has been a steady increase in the number of companies filing for Business Rescue and, is testament to the pressure placed on businesses during the current global economic crisis. Chapter 6 of the Act 2008 introduced principles relating to corporate rescues which bring us in line with international principles of turnaround and corporate rescue as they exist in foreign jurisdictions. Business Rescue was a fairly new concept to the local market and, initially the success rate of the process was disappointing. With time and the emergence of trained practitioners, there has been a distinct change in attitude to and acceptance of Business Rescue as an alternative solution that considers the best interests of all parties involved. The latest CIPC statistics show how liquidations have decreased from 5001 in 2010 to 3456 in 2013. This change can be attributed to a number of reasons; the most significant though is the change in mind-set towards accepting business rescue as a credible process to find the best outcomes for all concerned: §§Banks, the South African Revenue Service (SARS) and other major national creditors have familiarised themselves with the process and can see the benefit of it compared to liquidation proceedings §§Post Commencement Finance is more readily available due to a shift in perception and increased credibililty of the process §§The handful of practitioners, attending to the majority of assignments in South Africa, are more experienced and have learned how to implement the Business Rescue processes, first introduced in Europe, to the local market The statistics reveal that the majority of companies entering business rescue have been trading for between 5 to 10 years. The process is favoured by private (Pty) companies, followed by Closed Corporations (CC). Since 1 January 2013, almost 70% of all the assignments in South Africa have emanated from Gauteng whilst 82% of companies are entering the process via resolution. BUSINESS RESCUE AIMS TO: §§Rescue financially distressed businesses (not natural persons or trusts) §§Support government’s objective to create and maintain sustainable and productive work opportunities §§Avoid liquidations (where possible) From statistics at hand on 18 February 2014 the assignments commencing during 2011 and 2013 ended as follows: 2011 §§5% – Set aside Business Rescue proceedings §§20% – Substantial implementation of a Business Rescue plan §§30% – Liquidation §§45% – Conclusion of Business Rescue proceedings 2013 §§9% – Liquidation §§41% – Substantial implementation of a Business Rescue plan §§50% – Conclusion of Business Rescue proceedings DANIËL TERBLANCHE Director: Business Rescue Services [email protected] COMPASS JUNE 2014 3 SETTING ACHIEVABLE FINANCIAL GOALS When setting achievable financial goals there is only one place to start. You have to look at your personal budget. Determine how much you can afford and how much you need to put away. The next step is to split your goals into three pockets; short, medium and long term. Short-term could be saving up for a holiday, medium term buying a house, and long term is for retirement. To establish how much funds will be required to provide a specific monthly income, a simple calculation can be used. For basic planning you can assume that for every R10 000 you need per month today, you need approximately R2.4 million to provide a sufficient income until you die. But if you are going to retire sometime in the future you still need to consider inflation going forward. Every ten years, the amount of money you would need per month should double in your calculation to make provision for inflation at around 7% per year. If you have 20 years until retirement, you’ll need R40 000 per month (equal to R10 000 today) and retirement in 30 years will mean R80 000 per month in retirement which ultimately means you’ll need R9.6 million to earn the equivalent of R 10 000 per month in today’s value. If your income requirement is R20 000 today the capital figure doubles to R19.2 million in 30 years’ time. These figures are scary, but starting early makes them possible to reach. If you’re in your 20’s, it could mean saving R1 000 per month, but if you start in your 40’s, you’d have to save in excess of R10 000 per month to reach the same goal. Both figures assume a long term return of 14% per year and increasing your investment by 10% every year. Remember that your retirement income requirement should be less than income needed leading up to retirement. By the time retirement arrives, lifestyle expenses have changed and generally retirement income is planned at around 75% of your last earnings. In other words, if your projected salary earnings prior to retirement amounts to say R 50 000 then retirement income earnings generally are around R 37 500 per month. This can be justified by expenses that should cease at retirement (or prior) like bond payments, education costs (hopefully!) and contributions towards pension funding. Just be mindful of the escalation of medical costs as you get older, this may mean upgrading your medical plan gradually as you get older. This obviously implies that your future budget will continuously be tilted more towards medical expenses as you get older. Mazars Financial Services is an independent Financial Services Provider providing our clients with solutions that add value to them and their investments. Building portfolios and managing the risk associated with investing is a responsibility we are adequately equipped to handle. Speak to one of our expert financial advisers to assist with your financial planning. 4 MAZARS If you’re planning to buy a house as the bulk of your retirement savings, think again. Don’t tie all your capital in a property or anticipate that the profit when downsizing will be sufficient to live off. Extra money should be halved – 50% into your home loan and 50% in to savings. lose the real value of your investment over time. Historically there are very few periods where the after tax returns of cash beat inflation. If you cannot beat inflation, then you might as well spend your money because you will not be able to afford the items in the future that you are supposedly saving for. Furthermore, downsizing often means moving into a security estate and because of the security aspect these options typically cost more per square metre than a free standing house. The selling and buying costs of property will erode your anticipated profits substantially. We too often see individuals with a substantial residence and too little retirement capital as a result of the old folk lore of paying all additional funds into your bond. The long term returns of the stock market are substantially higher that mortgage bond rates over any meaningful period. This only magnifies the longer the investment is made and the power of compound growth comes into play. Cash is only best if you plan to use your savings within six to twelve months. Between 6 months and two years consider investing in specialist income funds, a year to three is good for stable-type fund investments with limited equity exposure, three years plus for balanced funds with more equity exposure and four years or more should mean a high exposure to equities. You must decide where to invest and for what term based on your risk adversity and risk profile. Most importantly – do not change your objectives and investment terms. This usually leads to capital losses. It is vital to support all your goals, be they for emergency purposes or to build sufficient reserves. If you’re not disciplined, use a retirement annuity (RA) for your retirement rather than a discretionary portfolio of unit trusts (though there are RAs that allow you to invest into unit trusts through the RA). The liquidity constraints within an RA will prevent you from ‘dipping in’ to your savings. This is one of the main culprits currently causing under-funding at retirement. Do not discount the tax benefits of RA’s, both on the contributions as well as returns within the RA. RA’s also provide substantial estate planning benefits. More about all these benefits later… If you are averse to investment risk/volatility, you need to realise it may take longer to save enough for your goal as a result of conservatism. The more time you have, the more aggressive your savings can be with exposure to riskier (more volatile) asset classes such as equities. The problem is that we focus too much on shortterm goals, and market volatility is confused with capital risk. It’s really important, however, to avoid losing money if you’re sitting with cash. Cash is the one asset class that you are almost guaranteed to KILL BAD DEBT Anything that is charging interest of prime plus 2% or more must go (especially where depreciating assets were financed). Overdrafts and credit cards are often also culprits charging excessive interest. One place where debt can work in your favour is a bond on rental property. Do not reduce the bond on rental property aggressively, take advantage of the tax benefits for as long as you can. If you can, accumulate an emergency fund of 3 times your monthly salary. But if your access to credit is reasonable and cost-effective you should rather put your saveable income towards reducing debt and boosting your longer-term savings. MARIUS FENWICK COO, Mazars Financial Services(Pty)Ltd [email protected] COMPASS JUNE 2014 5 CYBERSECURITY IS BIG BUSINESS! Cybersecurity is the body of technologies (new and old), knowledge basis, processes and practices designed to protect networks, computers (everything from laptops to mainframes, iPads to cell phones etc.), programs and data from attack, damage or unauthorised access. The term security covers all dimensions within the computing context, and is collectively referred to as cybersecurity. At its 24th Annual World Congress, the Information Security Forum (ISF) declared that Cyber Crime, Data Privacy and Reputational Damage are among the top six Information Technology (IT) security threats for 2014. This is driven mainly by greed, as people want to gain a competitive advantage through unscrupulous means, enrich themselves through illegal and nefarious means, gain greater market share, steal intellectual property (IP) and gain access to funds that do not belong to them. On the other hand it may be to prove they can gain access to confidential and non-disclosed information or even negate the integrity of data. Employees and other insiders, who by virtue of their position have access to companies’ confidential information, remain the greatest threat to the security of intellectual property. According to Jacob Olcott (Principal at Good Harbor Security Management), “The insider threat is hard to predict, hard to stop, hard to even detect, and can have major consequences. Access controls and privilege restrictions are an important part of the solution and should be revisited periodically.” THE RISKS Consider the consequences of: §§Gaining access to your competitors price list, when he is launching a special or submitting a tender §§Getting hold of someone’s cell phone, that is not password protected and contains their banking details – or is protected, but you have the free software to crack the code §§Accessing personal health or travel information §§Being able to intercept an email whenever you need to, so the recipient is either deprived of the content of the communication, or 6 MAZARS misinformation that will be considered 100% correct by the recipient is added Herein lies deviant sources to wealth, violation of personal privacy, the ability to control, contrive and determine the future and, is the essence of manipulation in the grey world of questionable ethics between individuals and businesses – and YES, some business and their executives are involved in this cyber squalor. WHY IS THIS IMPORTANT? Consider three major breaches in the past five months: §§The credit card and client details of approximately 40 million Target supermarket (USA) users were stolen. Target publicly proclaimed they would settle client accounts if clients could prove ‘it was not them who made the purchase’ §§The Heartbleed virus, which got its name because it is a flaw in the Transport Layer Security (TLS) and Device TLS protocols, is a vulnerability in some implementations of OpenSSL (open source program code) which allows an attacker to read up to 64 kilobytes of internet memory per attack (roughly 30-32 pages) §§A school project, run by two fourth-year Israeli students at the Israel Institute of Technology, hacked the incredibly popular Waze GPS map, an Israeli-made smartphone app that provides directions and alerts drivers to traffic and accidents. The students created a virtual traffic jam to show how malicious hackers might create a real one! WHAT IS BEING DONE ABOUT IT? On 26 March 2014, the American Securities and Exchange Commission (SEC) held a roundtable ‘to discuss cyber security and the issues and challenges it raises for market participants and public companies, and how they are addressing those concerns’. This Alert was issued because the SEC thought it would be helpful to summarise the responsibilities of the independent external auditor with respect to cybersecurity as it relates to the audit of the financial statements and, when applicable, the audit of Internal Control over Financial Reporting (ICFR). The financial reporting-related Information Technology (IT) systems and data that may be in scope for the external audit are usually a subset of the aggregate systems and data used by companies to support their overall business operations and may be separately managed or controlled. Accordingly, the financial statement and ICFR audit responsibilities do not encompass an evaluation of cyber security risks across a company’s entire IT platform and would need to be discussed and addressed. This exercise is still underway and is making good progress towards the national asset and infrastructure protection. WHAT CAN YOU DO? At this stage all we can do is be as secure as possible. We need to educate our users about the use of sound IT security policies, processes and best ‘fit-forpurpose’ practices and, implement, as well as comply with good cyber hygiene. That means, making sure we are protecting and maintaining systems and devices appropriately, in relation to the organisations in which we operate. An IT audit can assist align the IT unit with common business and operational strategies and, help identify and resolve deficiencies and vulnerabilities in IT systems, so as to enhance competitive advantage. We are aware of the importance of the integrity of IT infrastructure and systems, and offer services testing, assessing and providing advice on how to improve and protect these IT systems in a rapidly changing and constantly shifting environment. WHAT IS SOUTH AFRICA DOING ABOUT IT? Last year our government tabled the National Cyber Security Policy Framework for South Africa which recognises ‘that cybersecurity threats and the combating thereof have a national as well as an international context’, ‘thus a cyber strategy must appraise the vulnerability of a country’s critical infrastructure, devise a system of preventative measures against cyber attacks, and decide upon the allocation of tasks relating to cybersecurity management at the national level’ and ‘ improve the legal framework against cyber attacks’. FAIZAL DOCRAT Director: ICTA [email protected] COMPASS JUNE 2014 7 IMPLICATIONS FOR REAL ESTATE INVESTMENT TRUSTS (REITS) A Real Estate Investment Trust (REIT) is defined in Section 1 of the South African Income Tax Act No. 58 of 1962 (the Income Tax Act) as, a company that is a resident and the shares are listed on the Johannesburg Stock Exchange (JSE) as defined in the JSE Listings Requirements. The REIT regime affords certain tax advantages to qualifying entities. Despite the name referring to trusts, REITs are classified as companies. However, despite the tax advantages, there still remains other tax implications should other adjusting items exist on the tax computation of the company concerned. In accordance with the JSE Listings Requirements, a REIT will be required to distribute 75% of its ‘distributable profits’. ‘Distributable profits’ is defined in the JSE Listings Requirements as gross income, as defined in the Income Tax Act, less deductions and allowances that are permitted to be deducted by a REIT in terms of the Income Tax Act, other than the qualifying distribution as defined in section 25BB of the same act. Property companies will often become REITS whilst carrying assessed losses derived from ‘pre-production interest’, property allowances or the interest costs associated with high gearing. TAXATION OF A REIT REITS are entitled to deduct the amount of any ‘qualifying distribution’ incurred during that year of assessment by the REIT from its income. A ‘Qualifying distribution’ is defined to include, any dividend declared or interest incurred in respect of a debenture forming part of a property linked unit by a REIT or a controlled property company (CPC), during a year of assessment, if more than 75% of the gross income received by or accrued to such REIT or CPC, consists of rental income. This qualifying distribution may not exceed the taxable income calculated for the REIT or CPC, and should consist of at least 75% of the ‘distributable profits’ as required by the JSE. A CPC is defined as a company that is a subsidiary of a REIT. International Financial Reporting defines ‘subsidiary’ as ‘an entity that is controlled by another entity’. Section 25BB(4) of the Income Tax Act prohibits REITs and CPCs from deducting immovable property related allowances in terms of sections 11(g), 13, 13bis, 13ter, 13quat, 13quin or 13sex. As a result, the ability to create assessed losses is severely restricted. Section 25BB does not however, prevent REITs from deducting section 11(e) wear and tear allowances on qualifying assets owned and used by them, such as fitted carpets, generators, advertising boards, escalators, security systems, carports, lifts, demountable partitions, fire detection systems and air-conditioners. 8 MAZARS The most noteworthy benefit afforded to companies that qualify to be listed as a REIT is that in determining the capital gain or capital loss of a REIT, any capital gain or loss in respect of the disposal of immovable property or a share in a CPC must be disregarded. It should be noted however that REITs and CPCs are not specifically exempt from the recoupment of past wear and tear allowances deducted on immovable property. This is reflected in the resultant deferred tax liabilities being maintained by reporting REITs and CPCs, in terms of IAS 12. The qualifying distribution deduction formula, as it is currently contained in section 25BB(2) of the Income Tax Act, effectively requires REITs and CPCs to limit the deduction of qualifying distributions to the taxable income of a REIT or CPC, which is by definition determined before the deduction of any assessed loss. By preventing the erosion of assessed losses resulting from qualifying distribution deductions REITs will be able to maintain assessed losses until they can be utilised against taxable recoupments. IAS 12. The exemption from capital gains tax under section 25BB, only refers to the immovable property of the REIT. Examples of such other assets or liabilities are staff provisions, lease straight lining adjustments or movable property where allowances can be claimed under section 11(e) of the Income Tax Act. These other assets or liabilities will affect the calculation of taxable income for the REIT or CPC and, as a result, they affect the amount which the ‘qualifying distribution’ is limited to. Therefore, when setting up a REIT, the above factors should be taken into consideration. This article explains REITs and CPCs at a high level, as well as the IAS 12 implications. Companies are advised to seek tax advice should they consider becoming a REIT or CPC so as to gain a detailed and complete view of the tax implications. DEFERRED TAX As mentioned, there is a possibility of companies recouping tax allowances claimed on immovable property prior to the company becoming a REIT. In terms of IAS 12, deferred tax should be raised on this future tax consequence. It should also be noted that should a REIT have other assets or liabilities, which would ordinarily result in a timing difference in terms of IAS 12, those assets or liabilities will still fall into the requirements of TRACY DE ABREU Tax Consultant [email protected] COMPASS JUNE 2014 9 IFRS 10: TO CONSOLIDATE OR NOT TO CONSOLIDATE…? IFRS 10 CONSOLIDATED FINANCIAL STATEMENTS REPLACES PART OF IAS 27 CONSOLIDATED AND SEPARATE FINANCIAL STATEMENTS AND SIC-12 CONSOLIDATION – SPECIAL PURPOSE ENTITIES IFRS 10 is effective for financial years beginning on or after 1 January 2013. This new standard on consolidation replaces those sections of IAS 27 and SIC-12 that used to address how an entity determined whether its investments in other entities (investees) were subsidiaries, and should be consolidated. IAS 27 focused on voting rights. The standard presumed that when an entity owned more than half the voting rights in another entity, it controlled that entity and should therefore consolidate that entity (other than in exceptional circumstances). SIC-12 specifically addressed the consolidation of ‘SpecialPurpose Entities’ (SPE’s). SPE’s are entities designed in such a manner that they are not controlled by voting rights. For SIC-12, the focus was on benefits and risks; the entity carrying the majority of the benefits and risks of the SPE typically controlled the SPE. Control is still the fundamental concept when considering the level of investments, but IFRS 10 has introduced a new concept, ‘power’. The standard puts greater focus on which investor has power over the investee, the rights to returns generated by the investee, and the ability to use its power over the investee to affect the amount of those returns. The majority of voting rights, risks or rewards are no longer considered the only determining factors for control. In most cases the conversion from IAS 27 to IFRS 10 is expected to have little to no effect but, all investments must be assessed for control in accordance with this new standard. When considering IFRS 10 in the light of a typical company group structure (refer diagram 1 following), it may be clear that an investee (B) is controlled by means of equity instruments that give the holder the majority voting rights. In such a case, the investor (A) has power over B as a result of its majority voting rights, as it has power through those voting rights to affect the returns which it will receive. DIAGRAM 1 A 80% C B 20% In more complex cases, the party holding the majority voting rights will not be the dominant factor in determining who controls the investee. Additional factors will need to be considered, for example, when the following circumstances exist (inter alia): §§A’s rights to appoint or remove B’s key management personnel (such as directors) are not directly in proportion to its voting rights (e.g. C can appoint 80% of the board) §§B’s key management personnel is dominated by related parties of C §§Management agreements are in place over B’s ‘relevant activities’ (which are the activities of B that significantly affect B’s returns) §§C has rights to appoint another entity that directs B’s relevant activities §§Put and/or call options exist over the shares in B §§There is a possibility of ‘de facto’ control (discussed further later) 10 MAZARS In each of these circumstances A will need to assess whether it continues to have power over B and the ability to use its power to affect the amount of the returns that it is exposed to from its involvement with B. The assessment may result in a conclusion that C, or neither A nor C, now has power over C. De facto control can exist where an investor holds less than the majority of the voting rights in the investee, but practically still controls the voting process as it is the dominant investor in the entity while the remaining votes are held by widelydispersed shareholders. For example, say A holds 40 shares in B, while the other shareholders each own a maximum of 5 shares each (refer diagram 2). There are a total of 100 shares in issue, and each share carries one vote. Past voting patterns at annual general meetings indicates that B has historically controlled the voting process by casting 40 out of a total of 50 votes cast (even if another 50 votable shares were absent from the meeting) (refer diagram 3). As a result, A has “de facto” control and consolidates the investee until voting patterns change to indicate that A no longer controls the voting process. SHAREHOLDING (EACH SHARE CARRIES ONE VOTE) DIAGRAM 2 A other shareholders Max. of 5 shares each; total of 60 shares 40 shares PAST VOTING PATTERNS AT ANNUAL GENERAL MEETINGS DIAGRAM 3 A other shareholders 40 votes (i.e. 80% of total votes 10 votes (i.e. 20% of total votes B While IFRS 10 is unlikely to have much effect in most cases, its application should be thoroughly considered in more complex cases where the investor’s rights are affected by agreements that alter voting rights, rights to appoint key management personnel (such as directors), rights to practically manage the operations of the entity, and the like. It is of paramount importance to know what an investee’s relevant activities and influencing factors are. These should be monitored and management should be alerted in the event of a change, when a reassessment of control in terms of IFRS 10 should be performed in order to determine whether control is still appropriate to the investee, or whether control has become applicable to an investee that was not consolidated previously. B SUZANNA DE JAGER Director: Risk Management [email protected] COMPASS JUNE 2014 11 MEET THE KIMBERLEY TEAM Rapid economic growth and a burgeoning client base in the Northern Cape has prompted Mazars to firmly establish the firm’s presence in the region by putting down roots and opening a bigger office in Kimberley. With offices in Kathu and Bloemfontein already providing services to the region, the Kimberley office is further investment in the city and completes Mazars footprint in the Northern Cape. Mazars Kimberley is proudly local, yet can call on the collective intelligence of an international organisation backed by more than 13 800 professionals in 72 countries. The office is staffed by a dedicated multi-disciplined team that can provide superior audit, tax and advisory services across a wide range of public and private sectors. The Kimberley team is headed by the vastly experienced Latief Kimmie, who was born and raised in the city. He has extensive public sector experience having served as Deputy Provincial Secretary of the Northern Cape Provincial Legislature: Finance and Management Services. Thereafter he spent 12 years as Business Executive of the Office of the Auditor General in the Northern Cape, responsible for the audits of all three tiers of government in the Northern Cape i.e. National Departments, Provincial Departments and Local Government. Working alongside Latief are Brian Loudon and Carla Hugo. 1 6 5 3 7 7 1 9 8 6 4 2 1 4 1 7 9 3 3 1 2 9 4 7 6 8 Another local, Brian is a private sector expert, with vast experience working in the Agricultural, Medical, Small and Medium Enterprise (SME) and Technology sectors. Carla has experience spanning a wide variety of public, private and non-governmental (NGO) sectors. She is an outstanding performer and one of the regions brightest young stars. Come meet the team at our new offices at 76 - 78 Quinn Road, Kimberley. Contact us on 053 831 5490 or [email protected]. LATIEF KIMMIE CARLA HUGO BRIAN LOUDON Please send your comments/ideas to the editor [email protected] In South Africa, Mazars employs over 900 professionals in thirteen offices nationally. With the skills of 13 800 professionals operating in 72 countries, we’re big enough to service international listed clients, yet small enough to help small companies grow and prosper in their own environments. Mazars is represented in 22 African countries. level: evil The information in this publication should not be used as a basis for action without further professional advice. Detailed information available on www.mazars.co.za Contact your nearest Mazars office on 0861 MAZARS
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