South Africa Tax Agency Seeks Comments on Draft Bills, Regulations to Implement 2025 Budget Measures

The South African Revenue Service Aug. 16 opened a consultation on various draft bills and regulations to implement proposals made in the 2025 Budget. The draft bills and regulations include measures to: 1) reduce the income threshold for the ring-fencing rule on assessed losses; 2) remove the tax exemption for foreign retirement benefits received by South African residents under residence-based tax systems subject to DTAs; 3) amend the hybrid equity instrument definition to treat instruments recognized as debt liability under the International Financial Reporting Standards (IFRS) as debt for tax purposes; 4) address loopholes in the corporate reorganization rules on ...