The SAIT Corporate Tax Technical Work Group’s submission on the Draft Taxation Laws Amendment Bill, 2025 provides detailed commentary on proposed amendments to corporate tax provisions. The WG supports measures that enhance certainty, such as clarifying the order of applying deductions and assessed losses, but raises concerns that several proposals are overly broad and risk capturing legitimate commercial transactions. Key issues include the extension of anti-avoidance rules on third-party backed shares, the treatment of contributed tax capital in group structures, denial of roll-over relief for listed shares and CIS-related transactions, inconsistencies in the definition of “interest” under section 23M, and the inclusion of preference shares as exchange items. he WG stresses the need for carve-outs, clearer definitions, and guidance to avoid unintended consequences, safeguard commercial viability, and ensure alignment between policy intent and practical application.
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