The New South African Transfer Pricing Rules - Latest Developments

More than a year has passed since the announcement was made in the middle of 2010, that the South African transfer pricing rules would undergo a substantial redrafting process in order to align them with international best practice. In the meantime, the initially envisaged effective date of the 1 October 2011 has come and gone and the third updated version of the new section 31 of the Income Tax Act 58 of 1962 ("the Act") has just been introduced by the Minister of Finance to Parliament in terms of the Taxation Laws Amendment Bill, 2011 (No. 19 of 2011) ("the 2011 Amendment Bill"), which if promulgated in its current form, will come into operation on 1 April 2012, applying in respect of all financial years commencing on or after that date.