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Transfer Pricing
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
November 12, 2025
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  • Read this month's special features on VAT and Malta
  • I don’t know if it is because of my age, or not using social media much, or because I have spent more than 30 years advising companies that actually manufacture physical goods and sell them to customers, but I don’t really understand the current enthusiasm on the part of the OECD, the EU and governments to investigate ways to change the taxation of the ‘digitalised’ economy.
  • The tax treaty dispute resolution process is a critical and significant issue for multinational organisations and the OECD, which has invited taxpayers to be an integral part of the oversight process.

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