THE SUPREME COURT OF APPEAL
OF SOUTH AFRICA

Reportable

CASE  NO: 92/05

In the matter between :

THE COMMISSIONER OF THE SOUTH AFRICAN REVENUE
SERVICE
Appellant

- and -

BP SOUTH AFRICA (PTY) LTD
Respondent
_________________________________________________________________________
Before:
HOWIE P, STREICHER, NUGENT, CLOETE & HEHER JJA
Heard:
3 MAY 2006
Delivered:
25 MAY 2006
Summary:
Income tax – s 11(a) of Income Tax Act 68 of 1962 – interest paid
by company in respect of loan granted at time dividend declared
– loan obtained not to pay dividend but to produce income –
rental paid in advance in respect of long leases – expenditure of
capital nature.

Neutral citation:
This judgment may be referred to as  The Commissioner of
South African Revenue Services v BP South Africa (Pty) Ltd
[2006] SCA 60 (RSA)

_________________________________________________________________________

J U D G M E N T
_________________________________________________________________________

STREICHER  JA

STREICHER JA:
[1] This is an appeal by the Commissioner of the South African Revenue
Service (‘the Commissioner’) against a judgment in the Cape Tax Court
(‘the Tax Court’) upholding an appeal by BP Southern Africa (Pty) Ltd
(‘BPSA’) against the Commissioner’s income tax assessment for the 1993
year of assessment. In terms of the assessment the Commissioner
disallowed the deduction from income of interest in the amount of
R81 755 944 payable by BPSA in respect of a loan by its only shareholder
British Petroleum Company plc (‘BP plc’) and rental expenditure incurred
by BPSA in respect of filling station sites of R13 483 420 (less R31 008
and R71 464). The Tax Court held that these expenditures constituted
expenditures incurred in the production of income and that they were to be
treated as expenses deductible from BPSA’s income for the 1993 year of
assessment.

Deduction of interest
[2] BPSA markets petroleum products in South Africa. Some of the
petrol that it markets is refined by South African Petroleum Refineries, a
joint venture by BPSA and Shell. BP plc, the holding company of BPSA, is
a company incorporated outside the Republic. It required that dividends of
profits available for distribution be declared quarterly. As at 25 March
1990 BPSA held distributable profits amounting to R682 499 575 which it
would have liked to retain. BP plc on the other hand considered its
investment in South Africa risky, wanted to take the money out and insisted
that a dividend be declared. Eventually, in terms of an agreement reached
with the management of BPSA, a general meeting of the members of
BPSA, on 6 August 1990, resolved that the amount of R682 499 575 be
declared as a dividend and that a loan of R348 374 594 granted by BP plc
be accepted by BPSA. In terms of the loan granted by BPSA, interest at an

agreed rate was payable on the capital amount outstanding from time to
time. At the time BPSA had the necessary cash resources to pay the
dividend in full but as a result of the loan, only the difference between the
amount of the dividend and the loan (after deduction of the non-resident
shareholder’s tax, being an amount of R300 000 000) was remitted to BP
plc on 20 August 1990.

[3] Mr McClelland, the financial director of BPSA, who negotiated the
loan with BP plc, was the only witness who testified at the hearing of the
appeal in the Tax Court. He conceded that BPSA would have been better
off had the dividend not been declared in that the declaration of the
dividend brought about a liability to pay interest on the amount of the loan.
The payment of the dividend also brought about a lowering of the local
borrowing ceiling of BPSA imposed by the South African Reserve Bank.
For this reason a dividend would not have been declared had it not been for
the insistence of BP plc. The loan together with the partial restoration of
the local borrowing ceiling brought about by such loan was required to
fund various capital expenditure programmes which were being
contemplated by BPSA at the time. These included the expansion of the
refining capacity of South African Petroleum Refineries; maintaining other
parts of the refinery; the building of new service stations; re-branding them
in due course; and replacing delivery vehicles. The major item was the
expansion of the refinery. It would have been seriously disadvantageous to
BPSA not to have expanded the refining capacity of the refinery. However,
at the end of 1990 BPSA, notwithstanding payment of part of the dividend,
still had R427m in cash, which was more than was required to pay the
balance of the dividend in full. It would therefore have been possible to run
the business of BPSA until the end of 1990 but at some stage during 1991
the company would have experienced serious financial difficulties.

[4] In the event essentially all expenditure in respect of the refinery was
financed by way of hire purchase contracts and long term leases and at least
a substantial part of the loan was used as working capital. According to
McClelland the money, while it was in the bank, helped BPSA to overcome
shortfalls in working capital.

[5] The Commissioner disallowed the deduction of the interest on the
loan on the basis that it had not been incurred in the production of BPSA’s
income as required by s 11(a) of the Income Tax Act 58 of 1962 (‘the
Act’). The Tax Court overruled the Commissioner’s assessment and held
that the purpose of BPSA, in so far as the loan was concerned, was to
continue its income producing activities; and that the interest paid on the
loan was an expense incurred in order to produce income within the
meaning of s 11(a).

[6] Section 11(a) provides that there shall be allowed as deductions from
income, for the purpose of determining the taxable income derived by a
person from the carrying on of any trade, ‘expenditure and losses actually
incurred in the production of the income, provided such expenditure and
losses are not of a capital nature’. In order to determine whether
expenditure has been incurred in the production of income ‘important,
sometimes overriding, factors are the purpose of the expenditure and what
the expenditure actually effects’. (Per Corbett JA in Commissioner for
Inland Revenue v Nemojim (Pty) Ltd 1983 (4) SA 935 (A) at 947F-H). In
Commissioner for Inland Revenue v Giuseppe Brollo Properties (Pty) Ltd
1994 (2) SA 147 (A) at 152I-153D Nicholas AJA said:
‘[T]he enquiry relates primarily to the purpose for which the money was
borrowed. That is often the “dominant” or “vital” enquiry, although the ultimate user of
the borrowed money may sometimes be a relevant factor. Where a taxpayer’s purpose in

borrowing money upon which it pays interest is to obtain the means of earning income,
the interest paid on the money so borrowed is prima facie an expenditure incurred in the
production of income. See Commissioner for Inland Revenue v Allied Building Society
1963 (4) SA 1 (A) at 13C-G . . .

If, on the other hand, the purpose of the borrowing was for some other purpose than
obtaining the means of earning income (for example, to pay a dividend), the interest is
not deductible.’

[7] In Ticktin Timbers CC v Commissioner for Inland Revenue 1999 (4)
SA 939 (SCA) certain trading reserves and income were credited to the
loan account of Ticktin Timbers’ only member, Dr Ticktin, who had
bought the shares in a company which he had then converted into a close
corporation, Ticktin Timbers CC. Dr Ticktin contended that ‘he was
entitled to whatever dividends he wished to declare; and that all the credits
were passed in respect of dividends which he had declared but retained in
the business as an interest-bearing loan in order to finance its day-to-day
operations’.1 Interest was credited annually on the accumulated balance in
the loan account. This court had to decide whether the interest credited to
the loan account qualified as expenditure actually incurred in the
production of income. The issue was, therefore, the purpose for which the
loan was made.2 It was held that a scheme had been devised with the
obvious aim of ensuring that Dr Ticktin would be able to pay the interest
on the purchase price in respect of the shares he had bought and possibly
the purchase price itself. Hefer JA said: 3
‘I agree with the Court a quo that the loan was not needed for the appellant’s
income-producing activities and that the intention was to increase Dr Ticktin’s income,
not that of the appellant.’

1 943C-D.
2 943A-B.
3 944E-F.

[8] Counsel for the appellant contend that ‘the principle which emerges
from Ticktin is that, where the loan giving rise to the relevant liability for
interest is incurred pursuant to a scheme devised to benefit the shareholder
company and which results, not in additional income for the taxpayer, but
in an additional liability, then it cannot be said that the interest is incurred
in the production of the taxpayer’s income, for the purposes of s 11(a)’.
They contend that the evidence and documents clearly established that the
scheme upon which BPSA embarked, whereby it paid a dividend and at the
same time borrowed an equivalent amount from BP plc, was not conceived
in the interest of BPSA but was to serve the purposes of BP plc and in fact
created additional expenditure for BPSA in the form of interest on the loan
and not additional income.

[9] The fallacy in the argument is that a comparison is made between the
position of BPSA having declared the dividend and borrowed the money
and the position in which BPSA would have been, had the dividend not
been declared. In the circumstances of this case the position of BPSA
having declared a dividend and borrowed the money should be compared
with the position that BPSA would have been in had the dividend been
declared and had there not been a loan. In terms of the articles of
association of BPSA dividends are declared by the company in general
meeting. The policy of BPSA, insisted upon by BP plc, was that
distributable profits be distributed quarterly. When the dividend in issue
was declared there were distributable profits available for distribution and
there was cash on hand to pay the dividend. However, the management of
BPSA realised that cash would in a few months’ time be required to fund

capital expenditure programmes.4 It was because of this expected future
requirement that McClelland negotiated the loan with BP plc. He testified:
‘[T]here was a very sound and sensible policy on the part of the shareholders,
which I couldn’t gainsay as the local Finance Director, that if there was money which
could be taken out of South Africa, let’s take it out sooner rather than later and then
bring it back when needed so the shareholder’s interest would have been best served by
taking all the money and then bringing it back when needed. I didn’t like that because I
had no guarantee that when I needed the money I couldn’t sign deals to expand or the
company couldn’t sign deals to expand the refineries without knowing that the finance
was going to be there.’

[10] In these circumstances it would be illogical to regard the fact that the
loan was linked to the declaration of a dividend as an arrangement or
scheme conceived in the interest of BP plc. It was in fact an arrangement
conceived and concluded in the interest of BPSA which, insofar as the
dividend component is concerned, benefited BP plc and, insofar as the loan
component is concerned, benefited BPSA. The loan whether looked at in
isolation or in combination with the declaration of a dividend was,
therefore, seen from BPSA’s vantage point, a transaction concluded in the
interest of BPSA.

[11] The fact that the loan agreement was concluded in the interest of
BPSA does, however, not answer the critical question whether the money
was borrowed in order to pay the dividend or whether it was borrowed in
order to produce income. In Ticktin Hefer JA said in an alternative
approach, upon which the Commissioner also relied:5

4 Many years later Mr Featherstone in his capacity as Public Officer: BP Southern Africa (Pty) Ltd wrote
to the Commissioner that having declared a dividend it was necessary for BPSA ‘to retain cash resources
by way of a loan by the Parent in order to carry on its trading operations’. However, counsel for the
Commissioner correctly conceded that it made no difference whether it was foreseen that funds would in
a few months’ time after the declaration and payment of the dividend be required to fund capital
expenditure programmes or working capital.
5  At 944H-J.

‘A company or corporation is not obliged to pay a dividend or make a
distribution respectively irrespective of the financial circumstance in which it finds
itself. If after doing so, it will have the resources to enable it to continue its income-
earning activities without having to borrow simultaneously an equivalent amount no
problem arises. When it will not, but nonetheless pays a dividend or makes a
distribution and simultaneously raises a loan in exactly the same amount, it becomes a
question whether or not the purpose of the loan was to enable a dividend to be paid or
the distribution to be made or to provide the entity with liquid funds required to enable
it to pursue its income earning activities.’
Heher JA, in Commissioner, South African Revenue Service v Scribante
Construction (Pty) Ltd 2002 (4) SA 835 (SCA) at 841H, in respect of the
same issue but different facts, regarded surplus cash as the decisive factor.

[12] In the present case the evidence of McClelland was that if the
dividend had been paid in full, BPSA would have been able to continue
with its normal business activities including its capital expenditures until
the end of 1990 but would by the end of 1991 have had to find R440m.
BPSA did not therefore have simultaneously to borrow an amount to
replace the amount of the dividend or any part thereof. That, according to
the above quoted passage from Ticktin, should be the end of the enquiry.
But it seems to me to be nevertheless conceivable that a company may be
borrowing money to fund a dividend notwithstanding the fact that it has
resources available to enable it to continue its income-earning activities. I
shall therefore proceed on the basis that it nevertheless has to be
determined whether the purpose of the loan was to enable the dividend to
be paid or whether the purpose was to provide BPSA with the liquid funds
required to enable it to pursue its income-earning activities.

[13] After having concluded that, on the facts of Ticktin, the two
transactions were interdependent and that neither was intended to exist
without the other, Hefer JA said:6
‘It is this linkage which, to my mind, is fatal for appellant’s case for it shows
that the true reason why appellant had to borrow back at interest from Dr Ticktin money
which it had had in it own coffers and was under no obligation to part with was because
it wanted to make a distribution to Dr Ticktin.’

[14] Here it cannot be said that without the loan there would have been no
dividend. BP plc insisted on the dividend being declared and there was cash
available to pay that dividend. There was, therefore, no need to borrow
money to pay that dividend. It was clear that cash would in the future be
needed to carry on with the business of BPSA unless the business was to be
run down but that cash could have been raised at a later date by increasing
the issued share capital of BPSA or by a loan at that stage. In the
circumstances there is no reason not to accept the evidence of McClelland
that the money was borrowed to ensure that it would be available when the
need arose and not to pay the dividend.

[15] It follows that the Tax Court correctly held that the purpose of BPSA
insofar as the loan is concerned was to continue its income producing
activities and that the interest paid on the loan was an expense incurred in
order to produce income within the meaning of s 11(a). Insofar as the
interest of R81 755 944 includes interest on interest the Commissioner
agreed that, should it be held that the loan was an expense incurred in order
to produce income within the meaning of s 11(a), the interest on interest
was likewise incurred for that purpose. The appeal in respect of the interest
on the loan should therefore be dismissed.

6 At 945C.

Prepaid rental
[16] BPSA, like other oil companies in South Africa, is not allowed to
operate service stations. It sells its products to independent dealers who in
turn sell to the public. BPSA, therefore, has an indirect interest in the sale
of its petrol to the public and an interest in securing sites from which its
petrol can be sold. This is done by either acquiring such sites and leasing
them to dealers or by leasing sites from the owners thereof in terms of long
term head leases and subletting them to dealers. The sub-tenants may be the
owners themselves. We are concerned with the head leases which, in most
cases, were for periods of some 20 years. Each of the head leases provides
for the payment of rental by way of a lump sum in advance. These lump
sum payments put the owner in a position to build a service station where
no service station was in existence on the site, or to improve an existing
service station in accordance with the requirements of BPSA. The head
leases also provide for the registration of servitudes over the leased
properties as security for the repayment of prepaid rental in the event of the
termination of the lease by BPSA. In terms of the servitudes the lessor and
any other occupiers of the properties are precluded from selling any petrol
or petroleum products from the properties other than those supplied by
BPSA from time to time. McClelland testified that BPSA was not in the
business of hiring or letting property for the purpose of making a profit. He
agreed with the proposition that BPSA’s ‘purpose was to create a set-up
which would enable retailers to purchase petrol from BP which they would
in turn retail to the public’.

[17] The Commissioner contends that these lump sum rental payments,
R13 483 420 (less R31 008 and R71 464) in total, were of a capital nature
and therefore not deductible from income in terms of s 11(a). The Tax
Court held that the expenditures were deductible. It reasoned that if BPSA

had operated its own service stations on the leased properties the rental
payable would have been deductible as the premises would have been
occupied by BPSA for the purposes of its trade. Due to the prohibition
against BPSA owning service stations it had no choice other than to sublet
the premises to independent operators. It considered the rentals paid by
BPSA to have been expenditures which were ‘an essential part of the
business of (BPSA); it was the only way in which it could sell its products
and the expenditure incurred thereby was deductible’.

[18] Counsel for BPSA contend that the reasoning of the Tax Court is
correct. Their submission is that there is no material difference between a
lease in terms of which rental is paid by way of a lump sum ‘up front’ and a
lease in terms of which periodic rental payments are made.

[19] In Turnbull v Commissioner for Inland Revenue 1953 (2) SA 573
(A) at 579A-B Centlivres CJ said that rent is an expenditure incurred in the
production of income and that it is of a non-capital nature and therefore
deductible for the purpose of determining taxable income. In general that is
so but it would not always be the case. In this regard Wilcox J said in
Federal Commissioner of Taxation v Creer 65 ALR 485 (FC) at 493 (25-
35):
‘Ordinarily, of course, rental payments, made to obtain the right to occupy
premises used for the purpose of earning assessable income, are deductible. But
ordinarily such payments are recurrent; and ordinarily they bear a relationship to the
income expected to be earned by virtue of that occupation during the relevant
accounting period. Where those features are absent, it is better to set aside nomenclature
and to examine the substance of the transaction and – where relevant – the purpose for
which it was undertaken.’
[20] In Regent Oil Co Ltd v Strick [1965] 3 All ER 174 (HL) the  House
of Lords was dealing with four contracts in terms of which garage owners

were tied by way of a lease and a sublease to sell an oil company’s petrol.
The consideration for the lease was an agreed lump sum payment plus a
nominal rent of one pound per annum. In two of the four cases the lump
sums were expressly stated to be premiums while in the other two they
were not. It was held that the lump sum payments were of a capital nature.
It is true that some of the law lords drew a distinction between rent and a
premium.  Their view was that rent is paid for the use of property and is a
revenue expenditure7 whereas a premium is a capital expenditure as it is a
payment for the acquisition of an asset, being the right to use the property
for the purpose of carrying on a trade.8 However, whether a payment is
made for the use of property or whether it is made for the right to use
property the payment is a rental payment. In this regard I agree with the
following statement by Lord Reid in Regent:9
‘It was argued that a rent and a premium paid under a lease are paid for different
things – that the premium is paid for the right but that the rent is for the use of the
subjects during the year. I must confess that I have been unable to understand that
argument. Payment of a premium gives just as much right to use the subjects as
payment of a rent and an obligation to pay rent gives just as much right to the whole
term of years as payment of a premium.’

[21] It is not the legal categorization of a payment which determines
whether it is of a revenue or a capital nature.10 The mere fact that a
payment constitutes a payment of rental does, therefore, not qualify it as a
revenue expenditure. As in the case of every other expenditure ‘the true
nature of each transaction must be enquired into in order to determine
whether the expenditure attached to it is capital or revenue expenditure’.

7 At 197A-B and 201G.
8 At 197C-F and 201G; see also Brownlie and Jooste ‘The Lease Premium Concept in South African Tax
Law’  Acta Juridica 241.
9 At 180I to 181A.
10 See Hallstroms Proprietary Limited v The Federal Commissioner of Taxation (1946) 72 CLR 634 at
648.

(Per Watermeyer CJ in New State Areas Ltd v Commissioner for Inland
Revenue 1946 AD 610 at 627.) Again the purpose of the expenditure is an
important factor in determining the true nature of a transaction. If the
expenditure is incurred for the purpose of acquiring a capital asset for the
business it is capital expenditure.11

[22] In the present case the purpose of the lump sum payments ‘up front’
was to secure sites from which BPSA’s petrol could be sold. The
registration of the servitudes referred to above ensured that the sites would
be used for this purpose, even after termination of the leases by BPSA, for
as long as prepaid rental remained in the hands of the lessor. The
expenditures were, therefore, intended to secure sites from which BPSA’s
petrol could be sold even in situations where there was no lease. By paying
the lump sums BPSA secured these sites for a period of some 20 years ie it
acquired assets which were intended to endure for 20 years and which were
going to produce income for 20 years without any further expenditure
required in respect of the acquisition of the assets.

[23] A test that has been adopted to assist in the determination whether
expenditure is of a capital or revenue nature is to ask whether the
expenditure is more akin to the income producing operations of the
taxpayer or whether it is more akin to the income-earning structure of the
taxpayer, or to ask ‘is it expenditure required to carry on a business or is it
required to establish a business?’. 12 Money spent in creating an income –
producing concern is capital expenditure; it is invested to yield future

11 New State Areas Ltd supra at 627.
12 New State Areas Ltd v Commissioner for Inland Revenue 1946 AD 610 at 620-621; Secretary for
Inland Revenue v Cadac Engineering Works (Pty) Ltd 1965 (2) SA 511 (A) at 522B; Hallstroms
Proprietary Limited v The Federal Commissioner of Taxation (1946) CLR 634 at 646-647; and Regent
Oil Co Ltd v Strick (Inspector of Taxes) [1965] 3 All ER 174 189-190.

profit.13 In this case the purpose of BPSA was to establish a base for its
income-producing operations for the next 20 years. In the circumstances
the lump sum expenditures are more closely related to the income-earning
structure of BPSA than its income-producing operations. They were
incurred not to carry on the business of BPSA but to establish it. Through
the payment of a lump sum BPSA acquired an asset which, in the words of
Lord Wilberforce in Regent14, ‘was a source or foundation for the earning
of profits, through orders for petrol . . .: it can fairly be described as a piece
of fixed capital which is to be used in order to dispose of circulating
capital’.

[24] To allow these lump sum payments as a debit against income would
distort the profit for the particular year in that the profit for that year would
be unduly diminished and it is only after 20 years that a fair result would be
reached. This is a consideration that weighed with Lord Reid in Regent. He
said15 ‘recurrence as against a payment once and for all has (ever since
Vallambrosa Rubber Co Ltd v Farmer (Surveyor of Taxes) (1910) 5 Tax
Cas. 529) been accepted as one of the criteria in a question of capital or
income’ and added that he ‘would have great difficulty in regarding a
payment to cover twenty years as anything other than a capital outlay’.16
Lord Wilberforce said:17
‘No rule can be laid down as to a minimum period of endurance for a capital
asset or a maximum permissible period for an item of stock or circulating capital,
though obviously the more closely the period of endurance is related to an accounting
period the easier it is to argue for a revenue character, but no doubt there is a penumbra
the width of which may vary according to the nature of the trade.’

13 Commissioner for Inland Revenue v George Forest Timber Co Ltd 1924 AD 516 at 526.
14 At 202G.
15 See also Commissioner for Inland Revenue v George Forest Timber Co Ltd supra.
16 At 181B-F; see also 200A (per Lord Pierce).
17 At 204H-I.

[25] In the light of the nature of the payments, being lump sums, the
nature of the advantage obtained, being security that BPSA’s  products
would be sold from the leased premises, and the substantial periods
involved, I am of the view that the expenditures were of a capital nature.
My reasons are essentially the same as the reasons advanced by Lord
Wilberforce in Regent18 for concluding that the lump sum payments dealt
with in Regent were capital and not revenue payments. In one of the other
speeches in Regent Lord Morris of Borth-y-Gest expressed agreement with
the conclusion of Lord Denning MR in the Court of Appeal, which
conclusion is particularly apposite to this case and reads:19
‘The company make a payment once and for all. In return they get an advantage
which is of enduring benefit to the company. It brings in revenue to the company week
after week, and month after month, from the petrol they supply to the retailer. I have no
doubt this advantage is a capital asset and the payment for it is capital expenditure.’

[26] The parties were agreed that should it be held that the lump sum
payments constituted expenditure of a capital nature, s 11(f) would be
applicable.20 It follows that the appeal should be dismissed in respect of the
deduction of interest on the loan by BPSA plc but that it should succeed in
respect of the prepaid rental to the extent that BPSA is not entitled to a
deduction in terms of s 11(a) but is entitled to a deduction in terms of
s 11(f). Counsel for the Commissioner suggested that should this be our

18 At 205A.
19 Regent at 188B-C.
20 Section 11(f) provides as follows:
‘11
For the purpose of determining the taxable income derived by any person from carrying on
any trade, there shall be allowed as deductions from the income of such person so derived –
...

(f) an allowance in respect of any premium or consideration in the nature of a premium paid
by a taxpayer for –

(i)
the right of use or occupation of land or buildings used or occupied for the
production of income or from which income is derived; or

...

(aa)
the allowance under subparagraph (i), (ii), (ii)bis or (iii) shall not exceed for
any one year such portion of the amount of the premium or consideration so
paid as is equal to the said amount divided by the number of years for which
the taxpayer is entitled to use or occupation, or one twenty-fifth of the said
amount, whichever is the greater.’

conclusion it would be fair to apportion the costs of the appeal 80:20 in
favour of BPSA. Counsel for BPSA on the other hand submitted that BPSA
should be awarded all its costs. In the light of the fact that the appeal is
successful to the extent mentioned above it would be fair to award the
Commissioner 20% of the costs of the appeal as requested by his counsel.

[27] The following order is made:
The appeal in respect of the interest in an amount of
R81 755 944 on the loan by British Petroleum Company plc to
the respondent is dismissed.
The appeal in respect of rental payments in an amount of
R13 483 420 (less R31 008 and R71 464) is upheld.
Paragraph 2 of the order by the Cape Tax Court is replaced with
the following order: ‘The respondent is directed to apply the
provisions of s 11(f) of the Income Tax Act 58 of 1962 in
respect of the rental expenditure of R13 483 420 (less R31 008
and R71 464).’
The appellant is to pay 80% of the respondent’s costs and the
respondent is to pay 20% of the appellant’s costs.

_________________
P E STREICHER
JUDGE OF APPEAL

HOWIE P)
NUGENT JA)
CLOETE JA)
HEHER JA)