South Africa: An overview of SARS’ Interpretation Note 127

TAX abstract

On 17 January 2023, the South African Revenue Service (SARS) released Interpretation Note 127 (Determination of the taxable income of certain persons from international transactions: intra-group loans) (IN127). The purpose of IN127 is to provide taxpayers with guidance on the application of the arm’s length principle, in the context of intra-group loans.

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