Africa Transfer Pricing Practice Guide
This publication demystifies transfer pricing from a South African perspective and provides a single source of commentary, case law, legislation and regulatory materials.
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Product description
This publication demystifies transfer pricing from a South African perspective and provides a single source of commentary, case law, legislation and regulatory materials.
Published in print (looseleaf) and online format in December 2021 and updated on a regular bass. Print updates are not included in the purchase prices and are issued on a pay-as-you-go basis.
Online format must be added to a Lexis+ base package. Visit www.lexisnexis.co.za/lexisplus for more information.
The OECD BEPS initiative has caused many countries across the world to review and implement transfer pricing legislation. Multinationals are aware that there is an increasing need to pay attention to developments in this area going forward. While transfer pricing is well documented in most of the developed world, this is not the case in Africa. This publication explains transfer pricing related rules and regulations, addresses typical transfer pricing issues and highlights deviations from OECD rules.
Table of contents
Commentary
Introduction and history
The arm's length principle
Legislation and supplementary guidance
Transfer pricing documentation requirements
Function, risk and asset analysis
Transfer pricing methodology
Comparability
Attribution of profits to permanent establishments
Specific transaction types
Non-compliance with the transfer pricing law and regulations
Other topics
Transfer pricing audits
Controversy
Statutory accounting considerations
Appendices
Glossary
Section 31 of the Income Tax Act Tabulation
South African transfer pricing law and regulations
Summary SARS Practice Note No. 7
