The SAIT International Business Tax Work Group provided feedback on the 2024 Draft Taxation Laws Amendment Bill, supporting clarifications on hyperinflationary currency translation, shareholding periods, foreign tax rebates on capital gains, and CFC income rules. However, they raised concerns about proposed changes to section 24I of the Income Tax Act, particularly the expanded definition of “exchange item” and the ring-fencing of foreign exchange losses. SAIT cautioned that these changes could create inconsistencies, penalize trading companies, and deviate from the original intent of section 24I. They recommended aligning the treatment of hybrid instruments with existing anti-avoidance provisions and suggested that section 20, rather than section 24I, be amended to manage exchange losses for non-trading entities. They also flagged minor drafting errors for correction.
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