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Transfer pricing | Section 31 tested

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Multinationals with South African group companies are required to adhere to South Africa’s transfer pricing legislation as found in section 31 of the Income Tax Act, 58 of 1962, which provisions in very simple terms require cross-border transactions (which include loans) to be conducted on an arm’s length basis.

Tax – understanding understatement penalty behaviours?

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On 1 October 2012 the understatement penalty regime was introduced to replace the additional tax regime. An understatement penalty is determined by applying the highest applicable percentage in the understatement penalty table.

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