The South African Revenue Service has recently published a draft interpretation note covering the special tax relief provisions for holding companies, as well as the related anti-avoidance rules designed to prevent misuse or abuse of those provisions. According to the draft interpretation note, A headquarter company is subject to tax in the same way as any other resident company, however it is entitled to certain relief from income tax, CGT and dividends tax which is not available to resident companies that are not headquarter companies. As a consequence of the special relief granted to headquarter companies they are also subject...