According to a draft binding general ruling issued for public comment by the South African Revenue Service SARS, transitional rules for the taxation of interest payable by SARS under section 7E are being set out in a bid to avoid double taxation when:
- a deemed accrual of interest occurs under section 7E; and
- in a prior year of assessment, either the whole or a part of that interest was included in the taxpayer’s income on the accrual basis.
The draft ruling specifies that interest paid to…