Jané Visagie

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.

One of the key issues that foreign investors in South Africa (ZA) need to consider is whether their activities in South Africa will create a Permanent Establishment (PE) and expose them to a corporate income tax liability in South Africa.