“participant”, in relation to an ‘arrangement’, means-

(a)     a “promoter”;

(b)     a person who directly or indirectly will derive or assumes that the person will derive a “tax benefit” or “financial benefit” by virtue of an “arrangement”; or

(c)     any other person who is party to an “arrangement” listed in a public notice referred to in section 35(2);

[Definition of “participant” substituted by section 40 of Act 44 of 2014 effective on 20 January 2015 and section 39 of Act 23 of 2015 effective on 8 January2016]

‘financial reporting standards’ means, in the case of a company required to submit financial statements in terms of the Companies Act, 2008 (Act No. 71 of 2008), financial reporting standards prescribed by that Act, or, in any other case, the International Financial Reporting Standards or appropriate financial reporting standards that provide a fair presentation of the financial results and position of the taxpayer;

‘financial benefit’ means a reduction in the cost of finance, including interest, finance charges, costs, fees and discounts on a redemption amount;

‘arrangement’ means any transaction, operation, scheme, agreement or understanding (whether enforceable or not);