ARTICLE · 17 FEBRUARY 2022

Tax In Brief | Issue 78

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Below, please find issue 78 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

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Below, please find issue 78 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

LEGISLATION AND DRAFT LEGISLATION

Draft Interpretation Note | Determination of the taxable income of certain persons from international transactions: intra-group loans
- SARS' views on the application of the transfer pricing rules to thin capitalisation, and to intra-group loans more generally, were last expressed in a draft interpretation note issued in 2013.
- SARS has published for comment a new draft Interpretation Note which broadly follows the guidance in Chapter X of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, and addresses some aspects of the interaction of that guidance with the provisions of the Income Tax Act, 1962.

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