SARS ruling sheds light on offshore trust loans
BPR 430 considers a proposed distribution and set-off of reciprocal loan claims, but its tax outcome is confined to the particular facts presented to SARS.
#crossborderloan
Another amendment coming to curb tax avoidance when making an interest-free loan to a non-resident trust
The context to Treasury’s concern is where the arm’s length interest rate is lower than the official rate of interest.
