n SA Mercantile Law Journal = SA Tydskrif vir Handelsreg - Resolving Transfer-Pricing Disputes : are 'advance pricing agreements' the way forward for South Africa? : analyses

Volume 18, Issue 4
  • ISSN : 1015-0099
  • E-ISSN: 1996-2185



Extracted from text ... Resolving Transfer-pricing Disputes: Are 'Advance Pricing Agreements' the Way Forward for South Africa? ANNET WANYANA OGUTTU University of South Africa 1 Introduction and Statement of the Problem Adam Smith in his famous work The Wealth of Nations (1776) pointed out that the subjects of every state ought to contribute towards the support of the government in proportion to the revenue which they respectively enjoy under the protection of the state. However, the tax (contribution) which each individual is bound to pay ought to be certain and not arbitrary. The time of payment, the manner of payment and the amount to ..

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