Assertion: debt instrument's interest | /r/HasProperty | attributable
Facets:
Source sentences:
text: a non-resident company if the interest in respect of that instrument is attributable to a South African permanent establishment of that company; or
text: Even if an issuer has issued an instrument with equity-like features which falls within the scope of the definition of a hybrid debt instrument, section 8F will not apply to that instrument unless it has been issued a company that will take its interest deductions into account for South African tax purposes, ie the instrument must be issued by: a South African resident company; a non-resident company if the interest in respect of that instrument is attributable to a South African permanent establishment of that company; or a company that is a controlled foreign company if the interest incurred in respect of that instrument must be taken into account in determining the net income of that controlled foreign company as contemplated in section 9D of the Act.