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The key principle in tax law is that taxes follow the legal form of transactions unless specific anti-avoidance provisions apply, such as section 7c, or if a transaction is proven to be a sham. This means that the South African Revenue Service (SARS) can only disregard a loan account if it fails to meet common law criteria and is intended to be something else. Importantly, SARS cannot force the charging of interest on a loan; they can impose tax consequences if a loan is interest-free due to anti-avoidance provisions. For a transaction to qualify as a loan agreement, there must be a clear obligation to repay the amount lent.