On 20 January 2015, South Africa promulgated the Taxation Laws Amendment Act 2014, the Tax Administration Laws Amendment Act 2014, and the Rates and Monetary Amounts and Amendment of Revenue Laws Act 2014. Two key changes involve interest payment deduction limits, and the treatment of secondary adjustments. Interest Payment Deduction Limit The new rules for interest payment deduction limit for debt owed where there is a controlling relationship and the payment is not subject to South African tax in the hands of the lender are amended. In determining if a controlling relationship exists, the definition is changed from 20% to...