Rollover rules and asset for share swaps 

In the current economic climate many companies have limited access to credit and are acquiring assets against an issue of shares. Taxpayers acquiring equity with loan funding are seeking to make the interest expense incurred tax efficient. Companies within a group structure are being wound up.

In the transactions above the rollover rules are of extreme relevance and taxpayer’s need to understand the benefits and limitations of the provisions.

  • The outcomes of the live events has been mapped to the following competencies: Tax planning, Tax governance.
  • The live event is ideal for Continuing Professional Development and where required the necessary CPD accreditation is obtained from the professional body. For more information contact us.
  • We offer bulk registration discounts for group bookings on our live events. Please view our standard group booking rate card here. 
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Event hosted by
Diane Seccombe
Ideal for
Continuing Professional Development (CPD)
19 July 2023
Time (SAST)
This live event is recorded

Join us in this overview of specific rollover provisions and their use and benefit to private companies We will address:

Section 42, asset for share swap

  • Anti-avoidance provision and deemed capital gain and dividend
  • Effect on contributed capital
  • Effect of transfer of debt

Section 45 Intragroup Transactions

  • Mechanism to acquire equity tax efficiently 
  • De-grouping claw back
  • Use of debt in respect of asset transfer

Section 47 Liquidation, winding up of group companies

  • Qualifying assets

Assets acquired as consideration for shares issued


Sale of business assets

The index below represents the structure of the Live Event. You will be able to access the information contained within the index once registered. On the day of the event, you will head over to section 2 below where the Live Event will be streamed. 

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Meet the instructor

Diane Seccombe

Diane Seccombe is an admitted attorney with a masters degree in taxation. She has over 15 years of experience with taxation. Diane is currently the National Head of Tax Training at Mazars Academy Proprietary Limited and in this capacity provides tax training to professional institutes, banks, financial service providers and financial planners. She is also well known amongst students for her tax lectures at post graduate level. Diane consults on income tax matters including, corporate, individual and international tax and is an expert in Value Added Tax