(i)      in the case of any taxpayer who is a natural person, so much of the aggregate of any interest received by or accrued to his or her, other than interest in respect of a tax free investment as defined in section 12T(1), from a source in the Republic as does not during the year of assessment exceed—

(i)      in the case of any person who was or, had he or she lived, would have been at least 65 years of age on the last day of the year of assessment, the amount of R34 500; or

(ii)     in any other case, the amount of R23 800;

[Subparagraph (ii) substituted by section 6(1) of Act 23 of 2013 deemed effective on 1 March, 2013 and applicable in respect of years of assessment commencing on or after that date]

Provided that where any person’s year of assessment is less than a period of 12 months, the amount that shall be exempt from normal tax under subparagraph (i) or (ii) shall be the amount that bears to the amount referred to in that subparagraph the same ratio as the number of days in that year of assessment bears to 365 days;

[Paragraph (i) amended by section 7(a) of Act 72 of 1963, substituted by section 8(a) of Act 90 of 1964, by section 10(b) of Act 88 of 1965, by section 11(b) of Act 55 of 1966 and by section 8(1)(a) of Act 76 of 1968, amended by section 13(1)(d)-(f) of Act 89 of 1969, by section 9(1)(a) and (b) of Act 52 of 1970, by section 9(a) of Act 88 of 1971, by section 7(1)(a) of Act 90 of 1972, by section 7(1)(a) and (b) of Act 65 of 1973, by section 10(1)(f)-(h) of Act 85 of 1974, by section 9(b) of Act 103 of 1976, by section 8(1) of Act 113 of 1977, by section 4(1) of Act 101 of 1978, by section 7(1)(a)-(f) of Act 104 of 1979, by section 7(1)(b) and (c) of Act 104 of 1980, by section 8(1)(e)-(i) of Act 96 of 1981, by section 6(1)(b)-(g) of Act 91 of 1982, by section 9(1)(d) of Act 94 of 1983, by section 6(1)(c)-(e) of Act 96 of 1985, by section 7(c) and (d) of Act 65 of 1986, by section 3(1)(a)-(c) of Act 108 of 1986, by section 9(1)(e) and (f) of Act 85 of 1987, by section 10(1)(c)-(i) of Act 101 of 1990, by section 8(1)(n) of Act 36 of 1996, by section 21(1)(f) and (g) of Act 30 of 2000, by section 9(b) and (c) of Act 19 of 2001, by section 13(1)(a) of Act 30 of 2002, by section 36 of Act 12 of 2003, by section 26(1)(c) and (d) of Act 45 of 2003, by section 8 of Act 16 of 2004, by section 5 of Act 9 of 2005, by section 23(a)-(c) of Act 9 of 2006, by section 2(2)(b) and section 10(1)(f) of Act 8 of 2007, by section 1(2)(c) of Act 3 of 2008, by section 13(1)(d) of Act 17 of 2009, by section 18(1)(h) and (i) of Act 7 of 2010 and by section 28(1)(j) of Act 24 of 2011, substituted by section 28(1)(k) of Act 24 of 2011 and amended by section 14(1)(e) of Act 43 of 2014 and by section 5(1) of Act 20 of 2022 with effect from 1 March, 2023 and applicable in respect of years of assessment commencing on or after that date]

(cG)  the receipts and accruals of any person who is not a resident, which are derived by such person from carrying on business as the owner or charterer of any ship or aircraft, if a similar exemption or equivalent relief is granted by the country of which such person is a resident, to any resident in respect of any tax imposed in that country on income which may be derived by such person from carrying on in such country any business as owner or charterer of any ship or aircraft;

(hA)  any amount received by or accrued to the holder of a debt-

(i)      if the holder of that debt is a company that forms part of the same group of companies, as defined in section 41, as the issuer of that debt; and

(ii)     to the extent that the amount is attributable to any amount of interest as defined in section 23K(1) that is not deductible as a result of the application of section 23K;

(cE)   the receipts and accruals of any political party registered in terms of section 15 of the Electoral Commission Act, 1996 (Act No. 51 of 1996);

(h)     any amount of interest which is received by or accrues to any person that is not a resident, unless-

[Words preceding subparagraph (i) substituted by section 16 of Act 17 of 2017 effective on 18 December 2017]

(i)      that person is a natural person who was physically present in the Republic for a period exceeding 183 days in aggregate during the twelve-month period preceding the date on which the interest is received by or accrues to that person; or

[Subparagraph (i) substituted by section 22 of Act 23 of 2018 effective on 17 January 2019]

(ii)     the debt from which the interest arises is effectively connected to a permanent establishment of that person in the Republic;

(cA)   the receipts and accruals of –

(i)      any institution, board or body (other than a company as defined in the Companies Act, any co-operative, close corporation, trust or water services provider) established by or under any law and which, in the furtherance of its sole or principal object-

(aa)  conducts scientific, technical or industrial research;

(bb)   provides necessary or useful commodities, amenities or services to the State (including any provincial administration) or members of the general public; or

(cc)   carries on activities (including the rendering of financial assistance by way of loans or otherwise) designed to promote commerce, industry or agriculture or any branch thereof;

(ii)     any association, corporation or company contemplated in paragraph (a) of the definition of “company” in section 1, all the shares of which are held by any such institution, board or body, if the operations of such association, corporation or company are ancillary or complementary to the object of such institution, board or body:

Provided that such institution, board, body or company –

(a)     has been approved by the Commissioner subject to such conditions as he may deem necessary to ensure that the activities of such institution, board, body or company are wholly or mainly directed to the furtherance of its sole or principal object;

(b)     is by law or under its constitution –

(i)      not permitted to distribute any amount to any person, other than, in the case of such company, to the holders of shares in that company;

[Subparagraph (i) substituted by section 23(1)(c) of Act 31 of 2013 and by section 10(1)(a) of Act 23 of 2020]

(ii)     required to utilize its funds solely for investment or the object for which it has been established; and

(iii)    required on dissolution-

(aa)   where the institution, board, body or company is established under any law, to transfer its assets to some other institution, board or body which has been granted exemption from tax in terms of this paragraph and which has objects similar to those of such institution, board, body or company; or

(bb)   where the institution, board or body is established by law, to transfer its assets to –

(A)    some other institution, board or body which has been granted exemption from tax in terms of this paragraph and which has objects similar to those of such institution, board, body or company; or

(B)    to the State:

Provided further that –

(a)     where the Commissioner is satisfied that any such institution, board, body or company has during any year of assessment failed to comply with the provisions of this paragraph, he may withdraw his approval of the institution, board, body or company with effect from the commencement of that year of assessment;

(b)     where the institution, board, body or company fails to transfer, or take reasonable steps to transfer, its assets as contemplated in paragraph (b) (iii) of the first proviso, the accumulated net revenue which has not been distributed shall be deemed for the purposes of this Act to be an amount of taxable income which accrued to such institution, board, body or company during the year of assessment contemplated in paragraph (a); and

(c)     ……….