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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. Avail mid-December 2021.

Publication Language: English

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ISBN/ISSN: 20TRANSFPRSYS
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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. Avail mid-December 2021.

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.

 

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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