Overview
ENS, Taxand South Africa
In line with the trend in most developing countries, transfer
pricing has in the last years become a key focus area for the South
African Revenue Service ("SARS"). ENS' transfer
pricing team has, however, been involved in the area of transfer
pricing since the initial introduction of the transfer pricing
rules in South Africa in 1995.
ENS' transfer pricing team has extensive experience in all
areas of transfer pricing, inlcuding transfer pricing advisory
(i.e., detailed value chain analyses, characterisation of entities,
economic analyses and drafting of transfer pricing policies, also
taking into account areas such as corporate tax, indirect taxes and
customs, intellectual property law and exchange controls), transfer
pricing documentation, and transfer pricing dispute resolution
(i.e., assisting clients in respect of their interactions with SARS
and other tax authorities, from the initial risk assessment process
to potential
