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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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  • Yanira Armas
  • Rita Maria Silva
  • The Americas have recently seen a number of changes that will impact controversy matters. In December 2017, certain countries passed major tax legislation and there is an increased need for the use of alternative dispute resolution strategies to preclude the need of entering costly and unnecessary litigation. Additionally, funding across the taxing authorities varies greatly and will have an impact on the compliance approaches that the authorities may take to encourage voluntary compliance and deploy resources to the most significant non-compliance. Appropriate funding coupled with recently enacted tax legislation will likely impact the way audits will be conducted in the Americas.

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