25 March 2016 South African tax rules impacting inbound loan and hybrid financing arrangements Understanding and closely managing the potential tax risks and uncertainties associated with traditional South African inbound financing is becoming increasingly critical. In the Budget speech delivered on February 25, the South African National Treasury raised concerns about the excessive use of leverage by South African companies in order to reduce their tax burden through interest deductions. Further concerns were raised about the use of hybrid instruments and measures were proposed to address the issue of double non-taxation. A Tax Alert prepared by Ernst & Young South Africa, and attached below, provides additional details. Document ID: 2016-0565 |
