The laws surrounding transfer pricing are becoming ever more complex, as tax affairs of multinational companies are facing scrutiny from media, regulators and the public.

In the current global economic environment, transfer pricing is subject to much attention, particularly evidenced by the Organisation for Economic Cooperation and Development’s (OECD’s) initiative to address perceived base erosion and profit shifting (BEPS).

The South African Revenue Service (SARS) has taken to the BEPS initiative, as further evidenced by the Davis Tax Committee in 2014, and the Minister of Finance’s budget speech to Parliament in February 2015, 2016 and 2017. On 28 October 2016, SARS published a public notice that introduces compulsory transfer pricing record keeping requirements for taxpayers in relation to their cross border related party transactions with a value of more than R100 million.

Furthermore, in April 2016, SARS published specific draft regulations for country-by-country reporting and SARS has amended its income tax return (ITR) 14 to request additional transfer pricing information from taxpayers. This shows SARS’ increased focus on transfer pricing.

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Grant Thornton South Africa’s specialist transfer pricing team can assist you through all the phases of the transfer pricing life cycle:

  • planning and structuring transfer pricing
  • ensuring compliance and correct documentation
  • defending your position, and
  • operational transfer pricing, which focuses on implementing and managing the policies you've set. 

Contact us if your company has complex transfer pricing issues, or you need practical advice from an experienced transfer pricing specialist. Our services include:

  • developing a transfer pricing strategy that supports broader strategic goals
  • preparing and maintaining local, regional or global transfer pricing documentation
  • reviewing transfer pricing risk arrangements to identify potential areas of exposure
  • liaising with other Grant Thornton offices to solve issues in countries where your business operates
  • transfer pricing training
  • resolving transfer pricing disputes with tax authorities, and
  • pricing of intercompany debt and arm’s length debt testing.