Peter Dachs, ENS – Taxand Since their introduction in 1995, South Africa's transfer pricing rules have been based on a transactional approach, essentially requiring that an arm's length, that is, market-related price be paid or charged for the cross-border supply of goods or services between connected persons. According to the South African Revenue Service (SARS), the wording of section 31 of the Transfer Pricing Act caused structural problems and uncertainty, as it focused unduly on isolated transactions as opposed to arrangements driven by an overarching profit objective.
October 29 2012