Section 7C has been a hot topic for tax practitioners since its introduction in the Income Tax Act as part of the 2016 amendments. It is one of the few sections that most people recognise by the section number! SARS issued a draft interpretation note for comment late in November 2025. Although this document is only a draft, one can glean some insight into SARS’ approach and interpretation of the provision. In this episode, I look at some aspects of section 7C that are addressed in this draft interpretation note.

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