Hybrid debt instruments: an investigation of intercompany instruments payable on demand in terms of section 8f. in partial fulfilment of the requirements for the degree master of commerce in South African taxation

Section 8F of the Income Tax Act, No. 58 of 1962, was introduced as an anti-avoidance provision and its recharacterisation rules came into effect in respect of amounts incurred or accrued on or after 1 April 2014. Where the ambits of this section are applied to an intercompany instrument, the intere...

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