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Section 12B(1) and (2) of the Income Tax Act provides for a 50/30/20 income tax deduction in respect of certain machinery or plant owned by the taxpayer and which was or is brought into use for the first time by that taxpayer, for the purpose of his or her trade to be used by that taxpayer in the generation of electricity from, amongst others, photovoltaic solar energy (both for energy of more than 1 megawatt and energy not exceeding 1 megawatt) or concentrated solar energy. The tax deduction also applies to any improvements to the qualifying plant or machinery which is not repairs.
A Binding Private Ruling (BPR) 307 was issued by the South African Revenue Service on 4 July 2018 which deals with the application of DTA relief in respect of the double taxation of interest.