South Africa: Transfer pricing measures in 2017 budget | KPMG Global
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South Africa: Transfer pricing measures in 2017 budget

South Africa: Transfer pricing measures in 2017 budget

Among the measures concerning transfer pricing in South Africa’s 2017 budget (presented 22 February 2017) are proposals to update and align South Africa’s current transfer pricing guidance with the OECD Transfer Pricing Guidelines and to incorporate new guidance on the arm’s length principle and an agreed upon approach to the pricing of difficult to value intangibles.


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The budget provisions generally begin to incorporate recommendations from the OECD’s base erosion and profit shifting (BEPS) project. For instance:

  • Concerning country-by-country (CbC) reporting, for years of assessment commencing on or after 1 January 2016, South African multinational enterprises meeting local filing requirements must submit their CbC reports with the tax authority (SARS) within 12 months from the end of the relevant year of assessment. The CbC reports will provide SARS and other governments with the necessary information to identify transfer pricing risks.
  • Concerning mutual agreement procedure for dispute resolution, the South African treaty model will be updated to incorporate the minimum standards. However, South Africa has not committed to mandatory binding mutual agreement procedure arbitration.


Read a February 2017 report [PDF 443 KB] prepared by the KPMG member firm in South Africa

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