Deductions – Interest in re-organisations

tax planningAmongst the slew of amendments, was an amendment regulating the deductibility of interest incurred in respect of reorganisation transactions. The amendment will affect the structuring of reorganisation transactions, especially those that are debt funded, with significant consequences for the taxpayer.


The history
To understand these amendments, one has to go back a few years to June 2011 when section 45 of the Income Tax Act (the Act),