
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.

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.

Practitioners warn that applying section 7(8) to cross-border trust distributions could create onerous and potentially perpetual tax and compliance consequences.