South Africa's Tax Court recently delivered a landmark ruling in SARSTC IT 14302, addressing key transfer pricing principles. In our recent Tax Masterclass, our tax experts and the renown Wim Trengove discuss the implications.

South African companies with international operations face a unique challenge in the management and structuring of the ownership and use of intellectual property in their international operations.

Local media reports of 30 May 2014 announce that the Kenya Revenue Authority is investigating a number of Chinese companies suspected of evading tax.

The Discussion Draft on Transfer Pricing has been released. 19 July 2013, the OECD published the Base Erosion and Profit Shifting (BEPS) Action Plan, following the G20’s concern that current international tax rules and frameworks are inadequate to counter the perceived tax avoidance by multinationals.

On a high level, Advance Pricing Agreements ("APA") allow multinational entities to enter into an agreement with one or more tax authorities were the taxpayer(s) and revenue...

The Taxation Laws Amendment Bill, 2013 issued on 24 October 2013 (following the draft Bill issued 4 July 2013) proposes transfer pricing relief for loans with equity like features which have been extended by a South African company to its non-resident subsidiary, provided certain requirements are met.

The Davis Tax Committee ("DTC") recently addressed the issue of base erosion and profit shifting ("BEPS") in South Africa.

In February this year SARS published a Draft Interpretation Note on the determination of taxable income of certain persons from international transactions covering intra-group loans.

Clarificaition of the transfer pricing documentation.

A recent scenario involved a South African company structuring an intellectual property (IP) licensing agreement with an offshore partner.

It is important to identify individuals within a multinational group who understand transfer pricing and ensure that there is constant communication between these individuals.

In an ENSafrica article dated 19 August 2015, we addressed the proposed unilateral extension of prescription by SARS as was provided for in the draft Tax Administration Laws Amendment Bill...

The Minister of Finance, Tito Mboweni, presented his Medium Term Budget Policy Statement ("MTBS") today, 28 October 2020.

If not considered to be carrying on a trade, could the foreign exchange gains and losses on foreign debt instruments be considered to be interest?

A recent ruling by the Tax Court in the case of ABD Limited v CSARS marked a notable shift in how South Africa approaches disputes over transfer pricing.

On 15 December 2015, SARS issued a draft Public Notice that sets out the additional record-keeping requirements for transfer pricing transactions.

This marks an important step towards the finalisation of South Africa's transfer pricing documentation requirements.

The International Trade Administration Commission of SA (ITAC ) recently proposed 15% import duties on new energy vehicle (NEV) batteries, many of which currently...

Internationally, intra-group financing arrangements have been under scrutiny for a number of years and have been the subject of some of the most significant transfer pricing disputes.

Tax law is subject to frequent change.