Section 24I
Also known as: s24I, section 24I gains and losses
The Income Tax Act provision on exchange differences and certain financial instruments, which can require mark-to-market treatment for some holders.
Definition
Section 24I deals with gains and losses on foreign-currency exchange items and certain financial arrangements, and can require some taxpayers to account for unrealised exchange differences on a mark-to-market basis annually. Its application to crypto is nuanced and contested, but it is relevant where crypto is held by entities or in trading contexts that fall within its scope. Professional advice is important here.
Example
A company holding crypto in a way that falls within section 24I may have to recognise unrealised movements each year, unlike a long-term individual investor.
Jurisdiction notes
- South Africa: Section 24I can impose mark-to-market treatment on certain holders; its application to crypto is nuanced — seek advice.