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Alpha Holdings Ltd (a resident company) declared a dividend in specie consisting...

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Alpha Holdings Ltd (a resident company) declared a dividend in specie consisting of trading assets worth R500,000 to its shareholder, Beta Ltd, which is also a resident company and forms part of the same group of companies (as defined in s41). No written declaration or undertaking was submitted. Which of the following statements is most accurate regarding the dividends tax implications?

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