by Pieter van der Zwan | Sep 25, 2026 | Corporate and business tax
The 2013 Taxation Laws Amendment Act introduced section 23M into the Income Tax Act. This was around the time of the OECD BEPS project and its Action 4, which deals with limitations on interest deductibility. Most early commentary placed it alongside thin...
by Pieter van der Zwan | Feb 9, 2023 | Corporate and business tax
Interpretation note on intra-group loans SARS recently published Interpretation Note 127 (‘IN127’). It mainly deals with applying the arm’s length principle to intra-group loans, as the transfer pricing rules require. This complex area requires consideration of,...
