SARS issued BPR 163 - Interest on replacement loans and proceeds arising from a share repurchase.
This BPR published on 12 March 2014 deals with interest incurred on replacement loans and whether the loans will retain their initial business purpose for the interest on those loans to qualify for a deduction under section 24J(2). The ruling also deals with a share repurchase consideration received by a selling company and whether such consideration constitutes a dividend and consequently exempt from dividends tax and income tax.
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.