ARTICLE · 29 AUGUST 2017

Retrospective Country-By-Country Reporting And Transfer Pricing Documentation Requirements

ENS

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The filing obligation detailed in the draft notice appears to apply retrospectively for years commencing on or after 1 January 2016.

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South Africans who think that their tax burden is going to decrease because country-by-country ("CbC") reporting does not apply to their company should think again!

In addition to the recently released draft notice requiring the submission of CbC reports, master file and local file returns, the South African Revenue Service ("SARS") has recently issued the External Business Requirements Specification ("BRS") document, setting out CbC and Financial Data Reporting ("FDR") requirements.

South Africa's master file and local file requirements are in line with the Organisation for Economic Cooperation and Development's ("OECD's") requirements and South African taxpayers will now be obliged to submit transfer pricing-related returns.

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