Johannesburg - The exchange control charge imposed on Mark Shuttleworth formed part of a regulatory environment and was not a tax, the Constitutional Court heard on Tuesday.
Jeremy Gauntlett SC, for the SA Reserve Bank (Sarb), told the court: "The question is, is it a tax for the purpose of the Constitution or is it a charge that forms part of a regulatory environment?
"Our learned friends [Shuttleworth's counsel] say the former, we say the latter."