Does a change of the terms of a share constitute a new “date of issue” for purposes of section 8E of the Income Tax Act?
In terms of section 8E of the South African Income Tax Act, 1962 (the “Act”), dividends received by or accrued to a person in respect of certain shares and “equity instruments”, as defined, must be deemed in relation to that person to be an amount of income if that share or equity instrument constit…