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Foreign tax will generally adhere to the legal principle that the substance of a transaction reflects its legal form. An exception occurs if a specific anti-avoidance provision applies, such as section 7c, or if a transaction is proven to be a sham. For loan accounts, the South African Revenue Service (SARS) can disregard a loan only if it fails to satisfy common law loan criteria and is actually intended as something else. SARS cannot mandate the charging of interest on loans; instead, they can impose tax consequences using anti-avoidance provisions for interest-free loans. To qualify as a loan agreement, there must be a genuine obligation to repay a specified amount.