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Tax legislation traditionally distinguishes between returns on investment paid on equity and debt instruments. In the main, returns on debt instruments (interest payments) are deductible for the paying company, while distributions on equity instruments (dividends) are not. This difference in taxation can be exploited using hybrid instruments and often leads to a debt bias in investment patterns. South Africa, Australia and Canada have specific rules designed to prevent the circumvention of tax liability when company distributions are made in respect of hybrid instruments. In principle, Australia and Canada apply a more robust approach to prevent tax avoidance and also tend to include a wider range of transactions, as well as an unlimited time period in their regulation of the taxation of distributions on hybrid instruments. In addition to the anti-avoidance function, a strong incentive is created for taxpayers in Australia and Canada to invest in equity instruments as opposed to debt. This article suggests that South Africa should align certain principles in its specific rules regulating hybrid instruments with those in Australia and Canada to ensure optimal functionality of the South African tax legislation. The strengthening of domestic tax law will protect the South African tax base against base erosion and profit shifting through the use of hybrid instruments. [ABSTRACT FROM AUTHOR]

Although ocular diseases related to solar ultraviolet radiation exposure have a high prevalence in Africa, little is known about the occupational use of ocular photoprotective measures on the continent. In a survey of South Africa farmworkers on a farm in the Limpopo Province, we analyzed factors related to ocular sun protection including use of different types of hats and sunglasses in relation to age, gender and duration of agricultural employment. Majority of participants (80%) never wore sunglasses while 23% never wore a hat when working. More male workers used measures to protect their eyes than female workers. The type of hat most worn was a cap although broad-brimmed hats provide more effective photoprotection. The need for awareness campaigns that focus on the importance of using photoprotective measures in both an agricultural and South Africa contexts was identified., (© 2021 American Society for Photobiology.)

Background: Farmworkers in the Limpopo Province, South Africa, are at risk of excessive exposure to solar ultraviolet radiation (sUVR) due to both their work and the sUVR environment in the geographic area. However, the natural protection provided by this group's skin against sUVR has not been quantified. The aim of this study was to evaluate the subjective and objective skin colour of a group of farmworkers in order to classify the natural photoprotection provided by melanin and to evaluate the different measurement methods., Materials and Methods: Skin colour was established by using the subjective Fitzpatrick skin phototype system (FST) questionnaire and two objective methods, namely the individual typology angle (ITA°) and melanin index (MI). A total of 71 farmworkers participated in the study., Results: Black Africans tended to perceive their skin to be lighter than objectively measured, potentially due to cultural factors. The constitutive skin colour of most farmworkers was objectively classified in the FST V/brown group. Significant differences were found between the ITA° and MI of sun-exposed (constitutive) and non-sun-exposed (facultative) skin in Black African and White farmworkers. A strong correlation was found between ITA° and MI on different anatomical positions indicating both methods are appropriate to determine skin colour in deeply pigmented skin., Conclusion: The evaluation of skin colour with the use of both subjective and objective methods may be used to design an effective photoprotection programme for farmworkers in the Limpopo Province., (© 2020 John Wiley & Sons A/S. Published by John Wiley & Sons Ltd.)