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Witholding tax on interest in terms of shareholder loan from foreign entity

25 March 2014   (0 Comments)
Posted by: Author: SAIT Technical
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Author: SAIT Technical

The answer to this query is based on legislation as at 2014/03/25.

Q: Is there 15% withholding tax on interest on a rand based shareholders loan paid to foreign entity? 

A: Withholding tax on interest comes into operation on 1 January 2015 and is currently exempt in terms of s 10(1)(h) provided that the investor does not have a permanent establishment in the Republic. 


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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