{{item.videoDuration}}
{{item.title}}
{{item.text}}
{{item.videoDuration}}
{{item.text}}
Synopsis
A monthly journal, published by PwC South Africa, that gives informed commentary on current developments in the tax arena, both locally and internationally.
Through analysis of and comment on new laws and judicial decisions of interest, Synopsis helps executives to identify developments and trends in tax law and revenue practice that may affect their business.
In this edition:
Synopsis Tax today - October 2025
When a vanilla loan becomes subject to section 8F and is recharacterised as a ‘hybrid debt instrument’ mid-term, questions arise regarding the interplay between section 8F and section 24J(4) if the loan is subsequently transferred to a new holder. Our first article explores how section 8F’s reclassification of interest as dividends in specie intersects with section 24J(4)/(4A) on transfer of the instrument, and proposes a fair and reasonable approach to apportioning adjusted losses between historic (taxed) and recharacterised (untaxed) interest.
The development of a new UN Framework Convention on International Tax Cooperation (“UN Framework”) reflects a desire on the part of developing countries for a more broad-based and participatory approach to the formulation of rules of international taxation. While the objective of securing a fairer allocation of taxing rights is arguably both legitimate and necessary, one of the primary instruments in the UN Framework, namely a withholding tax on services, could be a potentially damaging tool if levied on a gross basis. The second article considers whether a heavy reliance on gross withholding taxes may create punitive tax burdens, heighten the risk of double taxation, and ultimately impose costs on the very developing-country businesses it is intended to help, with resultant impediments to long-term economic growth and investment.
{{filterContent.facetedTitle}}
{{contentList.loadingText}}
{{contentList.loadingText}}
Follow us
Contact us
