The South African Revenue Services (SARS) has launched a public consultation on the Draft Interpretation Note – Determination of the taxable income of certain persons from international transactions: Intra-group loans. The deadline for comments is 29 April 2022. --- Explanatory Note This Note, Determination of the Taxable Income of Certain Persons from International Transactions: Intra-group Loans, provides taxpayers with guidance on the application of the arm's length principle in the context of the pricing of intra-group loans. The pricing of intra-group loans includes a consideration of both the amount of debt and the cost of the debt. An intra-group loan...