Revised Debt Restructuring Tax Rules

The Taxation Laws Amendment Bill introduces a revised set of rules that will apply to debt restructuring transactions that occur during years of assessment that commence on or after 1 January 2018. The scope of the new rules are arguably wider than the existing provisions. Some relief is afforded in a domestic group context for dormant companies and debt capitalisation transactions.

The Taxation Laws Amendment Bill (TLAB) that was published by the National Treasury on 25 October 2018 contains a revised set of rules that apply to debt restructuring transactions. This article provides a high level overview of some of the changes that will take effect for years of assessment starting on or after 1 January 2018.