“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;