Transfer Pricing compliance requirements in South Africa have been significantly tightened and a modern transfer pricing system, including electronic transfer pricing return submission, has been put in place.
While the necessary legislative provisions to give effect to the proposed increase are still to be adopted by Parliament, one can accept that the Minister's proposal to increase VAT from 1 April 2018 will be implemented. A number of important issues need to be considered to ensure a seamless transition.
Transfer pricing relates to the transfer of goods or services between members of a multinational group which are tax residents in different countries. Instead of increasing existing taxes or levying new taxes, a way to tackle the looming budget deficit may be to properly implement transfer pricing rules and to ensure appropriate enforcement by the South African Revenue Service (SARS) of such rules.
The much-anticipated Draft Taxation Laws Amendment Bill came out on 19 July 2017. From an international tax perspective, issues of interest include the proposed changes and additions to the Controlled Foreign Company (CFC) rules. Of concern is the possibility that double tax might be payable in certain cases.
Tax authorities could do more to realise the full potential of new technology to reduce the tax compliance burden on taxpayers, according to the 2019 edition of the annual Paying Taxes 2019 Report, produced by PwC and the World Bank Group.
Multinationals in high-tax jurisdictions will now benefit from relaxed IP regulations. The 2017 Budget announced that the regulatory framework regarding cross-border intellectual property transactions is to be relaxed, for both tax and exchange control purposes.