Company Debt: Tax Risks and Pitfalls

Difficult economic times have led to many companies utilising more credit and defaulting on lending arrangements. Subordination clauses in loan agreements are being triggered and in certain situations debts are being waived or reduced including, for example, in business rescue negotiations.

Many taxpayers remain uncertain about the tax consequences of interest free loans, loans carrying excessive interest rates and further rules when the lenders are offshore.

  • 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)
15 June 2023
Time (SAST)
This live event will be recorded 

Please join us as we examine the tax pitfalls and benefits for companies in respect of debt. The areas under discussion will include:

Interest expense

    • Limitation of the interest expense deduction
    • Interest free loans

Conversion of debt to equity

    • Deemed donation
    • Effect on contributed tax capital

Debt waiver or reduction

    • When is the waiver of debt is tax free
    • Capital gains tax and recoupment of allowances and deducted expenses
    • Capital loss for creditor

Hybrid debt equity provisions

    • When an interest expense is deemed a dividend
    • New rules for the taxation of the lender
    • How to avoid deemed dividend when debt is subordinated

Transfer pricing 

Section 7C deemed donation and loans to companies


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