Hybrid Debt and Hybrid Equity Instruments and the Interest Limitation Rules in South Africa

Journal
South Africa
Bulletin for International Taxation 2015 (Volume 69), No. 3
In this article, the author examines the South African tax rules relating to hybrid debt and hybrid equity instruments, particularly with a view either to disallowing deductions or taxing receipts. Some observations are also made on the related interest limitation rules, which prevent excessive interest deductions.