13 May 2016

South African Treasury revisits hybrid debt rules to prevent double non-taxation

The South African National Treasury and the South African Revenue Service (SARS) hosted an industry workshop on May 12, to share initial views on hybrid debt rules avoidance schemes which they perceive to be of concern and the proposed measures that will be taken. This follows the announcement in the 2016 Budget Review, published on February 24, that measures will be taken to address double non-taxation arising in respect of hybrid debt instruments and surprisingly, that these new measures would come into effect on February 24 (i.e. retrospectively).

A Tax Alert prepared by Ernst & Young South Africa, and attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2016-0864

Document ID: 2016-0864