The Income Tax treatment of hybrid inter-corporate financial arrangements

Abstract

There are various ways to fund a corporate, the two most prevalent ways are through debt or equity. Revenue authorities can investigate a transaction, and if they are of the opinion that it has features or qualities that are better suited with an alternative type of transaction, they may recharacterize it and consider it as such for tax purposes. This research examines SARS/OECD reports which provides specific guidance on issues related to the pricing of financial transactions especially intra-group loans.