South Africa: Proposed amendment to rules allowing deferral of foreign currency gain or loss on certain related-party debts

Amendment is proposed to apply for years of assessment ending on or after January 1, 2026.

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August 19, 2025

Draft Taxation Laws Amendment Bill 2025 proposes amendments to section 24I(10A) of the Income Tax Act which allows for deferral of otherwise taxable “exchange differences” (i.e., foreign currency gain or loss) with respect to certain related-party debts, until the debt is satisfied.

In particular, the amendment would require that the debt or any portion thereof does not represent a current asset or current liability for IFRS purposes. The intention is that if a debt is no longer reflected in the financial statements of the taxpayer, the exchange differences in relation to the debt would no longer be deferred.

The amendment is proposed to apply for years of assessment ending on or after January 1, 2026.

Read an August 2025 report prepared by the KPMG member firm in South Africa

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