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Intra-group loans: Tax complexities

Intra-group loans: Tax complexities

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,...
Changes to the limitation on interest deductions

Changes to the limitation on interest deductions

by Pieter van der Zwan | Apr 20, 2022 | Corporate and business tax

The reduction in South Africa’s corporate tax rate to 27% coincides with two base-broadening measures that come into effect at the same time as the reduced rate. I considered the changes to the utilisation of assessed losses in an earlier article. This article...

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