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The indirect taxation of cross-border e-commerce transactions have been high on the agenda for tax authorities worldwide. There is clearly a perception that much of these transactions are escaping indirect tax (essentially VAT) because the supplier and consumer are in different jurisdictions.
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?