“Issuer” definition of section 24J of ITA

“issuer”, in relation to any instrument

 

(a)     means any person who has incurred any interest or has any obligation to repay any amount in terms of such instrument; or

 

(b)     at any particular time, means any person who, if any interest payable in terms of such instrument was due and payable at that time, would be liable to pay such interest;