The capital gains tax (CGT) legislation contains various so-called "adjustment rules" dealing with situations where, for example, proceeds received in respect of a disposal are either reduced or repaid, or expenditure is incurred, after an asset has already been disposed of. 

It seems, however, that these adjustment rules have also been used (incorrectly in National Treasury's view) when a contract for sale is cancelled (for example, by means of the non-fulfilment of a resolutive condition), which can lead to unintended CGT consequences.  

If a transaction is cancelled, National Treasury expects the parties to be restored to the status quo beforehand. Any anomalies in the legislation in this regard are to be removed.