2-Part Webinar: Interest deductions in respect of Cross-border Debt Funding
The landscape of interest deductions for cross-border debt funding has evolved significantly since the introduction of Section 23M into the Income Tax Act, effective from 1 January 2015. Over the years, this section has seen considerable amendments, reflecting the growing complexity of international financing arrangements and the need for robust measures to protect the South African tax base.
Section 23M was specifically enacted to address concerns around base erosion resulting from connected-party borrowing. Its primary objective is to limit excessive interest deductions on debts owed to persons who are not subject to tax in South Africa, thereby curbing the potential for profit shifting and ensuring the integrity of the country’s tax system.
In this series we unpack the provisions of Section 23M, explore real-world examples, and discuss strategies to navigate this evolving area of tax law effectively.
CPD/CPE: 3 hours