ARTICLE · 31 OCTOBER 2023

South Africa's Long-Awaited Advance Pricing Agreement Programme

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South Africa has recognised the importance of offering taxpayers greater certainty and predictability in their tax affairs through the recently proposed Advance Pricing Agreement ("APA") programme.

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South Africa has recognised the importance of offering taxpayers greater certainty and predictability in their tax affairs through the recently proposed Advance Pricing Agreement ("APA") programme. On 31 July 2023, the National Treasury released draft legislation for a proposed APA Programme through the Draft Tax Administration Laws Amendment Bill, 2023 ("Draft TALAB"). This draft bill includes a clause indicating that a chapter on the APA programme will be inserted into the Income Tax Act, 1962 ("the SA Income Tax Act"). It follows the release of a draft public discussion paper on the introduction of an APA programme, released in 2020 and the South African Revenue Service's ("SARS'") model draft legislative framework, released in 2021.

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