(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;

(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;

(gH)   any amount received or accrued in respect of a policy of insurance where-

(i)      the policy relates to death, disablement or illness of an employee or director, or former employee or director, of the person that is the policyholder; and

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

(ii)     no amount of premiums payable in respect of that policy on or after 1 March 2012 is deductible from the income of that person for the purposes of determining the taxable income derived by the person from carrying on any trade;

(gG)   any amount received by or accrued to a person as contemplated in subparagraph (ii) or (iii) of paragraph (d) of the definition of “gross income” –

  

(i)      in the case of a policy that is a risk policy with no cash value or surrender value, if the amount of premiums paid in respect of that policy by the employer of the person has been deemed to be a taxable benefit of the person in terms of the Seventh Schedule since the later of-

  

(aa)   the date on which the employer or company contemplated in those subparagraphs became the policyholder of that policy; or

(bb)   1 March 2012,

unless the amount of the premiums paid was deductible by the person in terms of section 11(a);

(ii)     in the case of any other policy, if an amount equal to the aggregate of the amount of any premiums has been included in the income of the person as a taxable benefit in terms of the Seventh Schedule since the date on which the policy was entered into;

(gE)   any amount awarded to a person by a beneficiary fund as defined in the Pension Funds Act;

(gD)   any funeral benefit payable in terms of section 6F of the Special Pensions Act, 1996 (Act No. 69 of 1996);

(gB)   any –

(i)      compensation paid in terms of the Workmen’s Compensation Act, 1941 (Act No. 30 of 1941), or the Compensation for Occupational Injuries and Diseases Act, 1993 (Act No. 130 of 1993);

(ii)     pension paid in respect of the death or disablement caused by any occupational injury or disease sustained or contracted by an employee before 1 March 1994 in the course of employment, where that employee would have qualified for compensation under the Compensation for Occupational Injuries and Diseases Act. 1993, had that injury or disease been sustained or contracted on or after 1 March 1994; or

(iii)    compensation paid in respect of the death of any person where that death arises out of and in the course of the employment of that person, to the extent that that compensation-

(A)    was paid in addition to any compensation contemplated in subparagraph (i) paid in that respect;

(B)    does not exceed an amount of R300 000; and

(C)    was paid by the employer of that person;

(iv)    compensation paid in terms of section 17 of the Road Accident Fund Act, 1996 (Act No. 56 of 1996);

(gA)   any disability pension paid under section 2 of the Social Assistance Act, 2004 (Act 13 of 2004);

[Paragraph (gA) inserted by section 7(1)(a) of Act 104 of 1980, substituted by section 29(1)(b) of Act 30 of 1998 and by section 9(1)(a) of Act 17 of 2023]

(e)

(i)      any levy received by or accrued to –

(aa)   any body corporate established in terms of the Sectional Titles Schemes Management Act, 2011 (Act 8 of 2011), from its members;

[Item (aa) substituted by section 11(1)(a) of Act 5 of 2026]

(bb)   a share block company as defined in the Share Blocks Control Act from the holders of shares in that share block company; or

[Item (bb) substituted by section 28 of Act 24 of 2011, section 23 of Act 31 of 2013 and section 14 of Act 43 of 2014 effective on 20 January 2015]

(cc)   any other association of persons (other than a company as defined in the Companies Act, any co-operative, close corporation and trust, but including a non-profit company as defined in that Act) from its members, where the Commissioner is satisfied that, subject to such conditions as he or she may deem necessary, such association of persons-

(A)    has been formed solely for purposes of managing the collective interests common to all its members, which includes expenditure applicable to the common immovable property of such members and the collection of levies for which such members are liable; and

(B)     is not permitted to distribute any of its funds to any person other than a similar association of persons:

Provided that such body, company or association is or was not knowingly a party to, or does not knowingly permit or has not knowingly permitted, itself to be used as part of any transaction, operation or scheme of which the sole or main purpose is or was the reduction, postponement or avoidance of liability for any tax, duty or levy which, but for such transaction, operation or scheme, would have been or would become payable by any person under this Act or any other law administered by the Commissioner; and

(ii)     any receipts and accruals other than levies derived by a body corporate, share block company or association contemplated in subparagraph (i), to the extent that the aggregate of those receipts and accruals does not exceed R50000;