Curbing Thin Capitalization: A Comparative Overview with Reference to South Africa’s Approach – Challenges Posed by the Amended Section 31 of the Income Tax Act 1962

The author, in this article, analyses, in an international comparative context, the effectiveness of South Africa’s measures to counter thin capitalization, in light of the 2011 amendments that merged the transfer pricing and thin capitalization rules. This article specifically considers the challenges that the new approach poses to taxpayers.