Dr. Hendri Herbst

The ratification of the SA/Kuwait protocol represents a pivotal development in the tax relationship between the two countries. The changes introduced by the protocol, particularly those related to dividends, have far-reaching implications for Kuwaiti, Dutch and Swedish investors in SA companies.

The South African Revenue Service will soon replace PN31 with section 11G of the ITA, governing deductions for expenses incurred in producing interest income. This will apply to years of assessment starting after 1 January 2025.

In 2024, South Africa proposed amendments to Section 7C of the Income Tax Act to curb tax avoidance through interest-free or low-interest loans to trusts, targeting cross-border transactions and clarifying the interaction with transfer pricing provisions, starting January 2025.