Hybrid Debt and Hybrid Equity Instruments and the Interest Limitation Rules in South Africa

Journal
Author
Mazansky, E.
Country
South Africa
Published Date
Issue
Bulletin for International Taxation 2015 (Volume 69), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

In this article, the author examines the South African tax rules relating to hybrid debt and hybrid equity instruments, particularly with a view either to disallowing deductions or taxing receipts. Some observations are also made on the related interest limitation rules, which prevent excessive interest deductions.