From Functional Analysis To Value Chain Analysis

Attacks by the South African Revenue Service ("SARS") on the transfer pricing practices of multinational enterprises ("MNEs") are on the rise, leading to tax disputes with SARS over significant amounts of tax.

MNEs operating in South Africa provide information to SARS in various forms such as annual Corporate Income Tax returns, Country-by-Country reports as well as the extensive Transfer Pricing documentation. It is therefore important to ensure that all information submitted to SARS in these various formats is aligned as any difference could assist SARS in challenging not only the Transfer Pricing policies but ultimately also the tax structure of the group as well as the substance of how a group operates across the globe.