As {News-2016-07-12/P/4- previously reported}, South Africa's 2016 Draft Taxation Laws Amendment Bill includes amendments to the anti-avoidance rules dealing with hybrid debt instruments. Under the current rules, interest payments made under hybrid instruments that include equity characteristics may be reclassified as dividends, which results in no deduction of the payments for the issuer and the levy of a 15% withholding tax on the deemed dividend. Two of the main amendments regarding the anti-avoidance rules are summarized as follows. Application of Rules to Non-Residents The anti-avoidance rules were expanded to cover non-resident debt issuers in 2013. An unintended result of the...