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Call for comment: Draft IN on determination of taxable income from international transactions

22 March 2013   (0 Comments)
Posted by: Author: SARS Legal & Policy
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Source: SARS Legal & Policy

SARS issued a Draft Interpretation Note on the determination of the taxable income of certain persons from international transactions: Thin capitalisation for public comment which can be found here.

This Note provides taxpayers with guidance on the application of the arm’s length basis in the context of determining whether a taxpayer is thinly capitalised under section 31 and, if so, calculating taxable income without claiming a deduction for the expenditure incurred on the excessive portion of finance.

SAIT will be making a submission to SARS. Kindly provide your comments by email to by no later than 28 June 2013. 


Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.


The Act requires that a minimum academic and practical requirments be set to register with a controlling body. Click here for the minimum requirements of SAIT.

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