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Taxation will generally align with the legal form of a transaction, except in certain circumstances. Specific anti-avoidance provisions may dictate different treatment, like Section 7C, or if a transaction is proven to be a sham, not reflecting its intended true form. For loan accounts, the South African Revenue Service (SARS) can disregard a transaction as a loan only if it fails to meet common law criteria of a loan agreement and was intended as something else. SARS cannot require interest charges on a loan; they can impose tax consequences through anti-avoidance provisions for interest-free loans. A valid loan agreement necessitates a genuine obligation to repay an amount.