“adjusted taxable income” means taxable income calculated before applying this section and before setting off any balance of assessed loss that has been carried forward from the preceding year of assessment-

(a)     reduced by-

(i)      any amount of interest received or accrued that forms part of taxable income;

(ii)     any amount included in the income of a person as contemplated in section 9D(2);

(iii)    any amount recovered or recouped in respect of an allowance contemplated in this Act in respect of a capital asset as defined in section 19; and

(b)     with the addition of-

(i)      any amount of interest incurred that has been allowed as a deduction from income;

(ii)     any amount allowed as a deduction in terms of this Act in respect of a capital asset as defined in section 19 for purposes other than the determination of any capital gain or capital loss;

(iii)     . . . . . .

[Subparagraph (iii) deleted by section 26(1)(b) of Act 17 of 2023 with effect from 1 January, 2024 and applicable in respect of years of assessment commencing on or after that date]

(iv)    any qualifying distribution as defined in section 25BB that is deductible under subsection (2) of that section;

: Provided that the result of the calculation may not be less than zero;

[Definition of “adjusted taxable income” amended by section 37(1)(a) and (b) of Act 43 of 2014 and by section 41(a), (b) and (c) of Act 23 of 2018, substituted by section 19(1)(a) of Act 20 of 2021 and amended by section 26(1)(a) and (c) of Act 17 of 2023 with effect from 1 January, 2024 and applicable in respect of years of assessment commencing on or after that date]

“controlling relationship” means a relationship where a person, whether alone or together with any one or more persons that are connected persons in relation to that person directly or indirectly hold at least 50 per cent of the equity shares or can exercise at least 50 per cent of the voting rights or participation rights, in a company;

[Definition of “controlling relationship” substituted by section 37(1)(c) of Act 43 of 2014, by section 19(1)(c) of Act 20 of 2021 and by section 26(1)(d) of Act 17 of 2023 with effect from 1 January, 2024 and applicable in respect of years of assessment commencing on or after that date]

“creditor” means a person to whom a “debtor” owes a “debt”;

[Definition of “creditor” added by section 26(1)(e) of Act 17 of 2023 with effect from 1 January, 2024 and applicable in respect of years of assessment commencing on or after that date]

“debt” includes any amount in respect of which interest is determined or incurred, and such amount must be regarded as owed, but does not include a tax debt as defined in section 1(1) of the Tax Administration Act;

[Definition of “debt” inserted by section 19(1)(d) of Act 20 of 2021 effective on 31 March, 2023 and applicable in respect of years of assessment ending on or after that date (effective date in section 19(2) of Act 20 of 2021 as substituted by section 10 of Act 19 of 2022)]

“debtor” means a person that incurs an amount of interest and-

(a)     is a resident; or

(b)     in the case of a person that is not a resident, owes a debt that is effectively connected with a permanent establishment of that person in the Republic;

[Definition of “debtor” substituted by section 37(1)(d) of Act 43 of 2014 and by section 19(1)(e) of Act 20 of 2021 effective on 31 March, 2023 and applicable in respect of years of assessment ending on or after that date (effective date in section 19(2) of Act 20 of 2021 as substituted by section 10 of Act 19 of 2022)]

“interest” means interest as defined in section 24J, and includes—

(a)     amounts incurred or accrued under any “interest rate agreement” as defined in section 24K(1);

(b)     any finance cost element recognised for purposes of IFRS in respect of any lease arrangement that constitutes a finance lease as defined in IFRS16;

(c)     amounts taken into account in determining taxable income in terms of section 24I(3) and (10A); and

(d)     any amount deemed to be interest under section 24JA,

but excludes any amount that is deemed to be a dividend in specie as contemplated in sections 8F and 8FA;

[Definition of “interest” substituted by section 19(1)(f) of Act 20 of 2021 effective on 31 March, 2023 and applicable in respect of years of assessment ending on or after that date (effective date in section 19(2) of Act 20 of 2021 as substituted by section 10 of Act 19 of 2022)]

‘issue’ ……….

[Definition of “issue” deleted by section 39 of Act 17 of 2017 effective on 18 December 2017]

“lending institution” means-

(a)     a bank; or

(b)     a foreign bank that is comparable to a bank,

contemplated in the Banks Act;

[Definition of “lending institution” substituted by section 26(1)(f) of Act 17 of 2023 with effect from 1 January, 2024 and applicable in respect of years of assessment commencing on or after that date]