n Business Tax and Company Law Quarterly - Embracing change - a new transfer-pricing regime

Volume 2, Issue 3
  • ISSN : 2219-1585


The purpose of this article is to explore the scope of the new proposed transfer-pricing regime which is to be introduced on 1 October 2011 in an amended section 31 of the Income Tax Act 58 of 1962. The article considers the new rules in an international context and in the light of the revised transfer-pricing guidelines issued by the Organisation for Economic Cooperation and Development ('OECD') in July 2010, as well as the legislative framework in Canada and recent case law developments in the United Kingdom. South Africa may well have achieved the aim of bringing its transfer-pricing regime in line with international developments. However, it remains to be seen how the new regime will be applied in practice. Tax authorities world-wide are becoming more sophisticated and aggressive. South Africa will be no exception.

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