Transfer pricing for intercompany agreements, management fees, intra-group services and intra-group loans in South Africa, in line with section 31 and SARS guidance.
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.
