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Tax Alert - Draft IN Thin Cap current version

Tax Alert25 March 2013 This Tax Alert is provided by PricewaterhouseCoopers Tax Services (Pty) Ltd for information only, and does not constitute theprovision of professional advice of any kind. The information provided herein should not be used as a substitute for consultation withprofessional advisers. Before making any decision or taking any action, you should consult a professional adviser who has beenprovided with all the pertinent facts relevant to your particular situation. No responsibility for loss occasioned to any person acting orrefraining from acting as a result of using the information in the Tax Alert can be accepted by PricewaterhouseCoopers Tax Services(Pty) Ltd, PricewaterhouseCoopers Inc or any of the directors, partners, employees, sub-contractors or agents ofPricewaterhouseCoopers Tax Services (Pty) Ltd, PricewaterhouseCoopers Inc or any other PwC entity. 2013 PricewaterhouseCoopers ( PwC ), a South African firm, PwC is part of the PricewaterhouseCoopers International Limited( PwCIL ) network that consists of separate and independent legal entities that do not act as agents of PwCIL or any other memberfirm, nor is PwCIL or the separate firms responsible or liable for the acts or omissions of each other in any way.

SARS releases draft Interpretation Note on Thin Capitalisation for comment On 22 March 2013 SARS issued the long awaited updated guidance on the thin capitalisation provisions of the Income Tax Act. The significant features of the Interpretation Note are summarised below. Application Arm’s length basis

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