“shareholder”–

(a)     in relation to any company referred to in paragraph (a), (b) or (d) of the definition of ‘company” in section 1(1) of the Income Tax Act, means the registered shareholder in respect of any share, except that where some person other than the registered shareholder is entitled, whether by virtue of any provision in the memorandum or articles of association of the company or under the terms of any agreement or contract, or otherwise, to all or part of the benefit of the rights of participation in the profits, income or capital attaching to the share so registered, that other person shall, to the extent that such person is entitled to such benefit, also be deemed to be a shareholder; or

(b)     in relation to any close corporation, means a member of such corporation; or

(c)     in relation to any co-operative, means a member of such co-operative;

[Definition of “shareholder” inserted by section 128 of Act 25 of 2015 effective on 1 April 2012 – Date of operation in section 128 of Act 25 of 2015 as amended by section 106 of Act 15 of 2016]