Transfer Pricing Insights
Practical South African transfer pricing guidance from Chantel Venter
SARS Interpretation Note 127 sets out how SARS tests intra-group loans: both the amount of debt and the interest rate. Here is what it means for South African borrowers and lenders.
Management fees are one of the most frequently questioned intercompany charges. Here is how to apply the benefit test, set an arm’s length charge and build the evidence SARS expects.
Intercompany agreements are one of the cheapest ways to reduce transfer pricing risk. Here is why SARS expects them and the clauses every agreement should contain.
South Africa finally has an advance pricing agreement programme. Here is who qualifies for the SARS APA pilot, which transactions are covered and how the process works.
Most transfer pricing adjustments are predictable. This guide sets out the red flags SARS looks for and a five-step process to identify and reduce your group’s exposure.
What happens in a SARS transfer pricing audit, how to respond at each stage, the deadlines that matter and practical steps to identify and reduce risk before SARS calls.
The short answer is a full search every three years and a financial update every year, but only if nothing has changed. Here is how to decide when your study needs refreshing.
A benchmarking study is the evidence that your intercompany prices are arm’s length. This guide explains how it works, step by step, and what SARS expects to see.
Every South African company with cross-border connected-party transactions must answer the transfer pricing questions in its ITR14. Here is what SARS asks and how to answer accurately.
A plain-language guide to SARS transfer pricing documentation: who needs a master file and local file, the R100 million and R5 million thresholds, CbC reporting, ITR14 disclosures and deadlines.
