Tag: Christian Wiesener

South Africa recently tightened its transfer pricing and disclosure requirements, implementing global standards. This was an important step to enable the South African Revenue Service (SARS) to enforce transfer pricing rules and to counter undesired base erosion through profit shifting. However, the question remains what else can be done to address impermissible transfer (mis-) pricing and to stimulate investment into South Africa, as tax collections have not been where they should be and it is expected that further expenditure will be proposed in the 2019 Budget?

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.

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.