ARTICLE · 30 SEPTEMBER 2014

Share Lending Arrangements – More Tax Changes!

ENS

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The securities lending industry has seen many changes to the taxation of share lending arrangements in South Africa during the last couple of years.

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The securities lending industry has seen many changes to the taxation of share lending arrangements in South Africa during the last couple of years. In particular, since the introduction of dividends tax on 1 April 2012, the provisions in the Income Tax Act (the "Act") which relate to the income tax and dividends tax treatment of dividends received by borrowers of JSE listed shares and payments made by such borrowers have been regularly amended, often with retrospective effect. The Draft Taxation Laws Amendment Bill which was released on 17 July 2014 ("2014 Draft Bill") is no exception, and again contains changes to the dividends tax provisions relating to payments made by such borrowers.

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