On 11 February 2022, the South African Revenue Services (SARS) published a draft interpretation note, determining the taxable income of certain persons from international transactions: intra-group loans and provides taxpayers with guidance on the application of the arm’s length principle in the context of the pricing of intra-group loans. The pricing of intra-group loans includes a consideration of both the amount of debt and the cost of the debt. The latest draft is issued for public comments. Comments must be submitted on or before 29 April 2022.