SARS issues Draft Interpretation Note on Intra-group Loans

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In February this year, SARS published a Draft Interpretation Note on determining the taxable income of certain persons from international transactions covering intra-group loans.

The note provides taxpayers with guidance on applying the arm’s length principle in the context of the pricing of intra-group loans. The arm’s length principle forms the basis of transfer pricing and is outlined in Section 31 of the Income Tax Act.

Section 31 applies before considering the impact of sections that limit the deduction of specific interest incurred on intragroup loans (section 23M) and interest incurred in relation to group restructuring (section 23N).

Download our latest article and learn more about Section 31.

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SARS issues Draft Interpretation Note on Intra-group Loans

In February this year, SARS published a Draft Interpretation Note on determining the taxable income of certain persons from international transactions covering intra-group loans.

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