The South African Revenue Service is seeking stakeholders’ comments on a draft tax law implementing a new advance pricing agreement (APA) program.Continue Reading
South Africa
Transfer pricing news, BEPS news, and international tax news in South Africa
South Africa seeking input on draft tax bills
South African Revenue Service has published for stakeholders’ comments draft tax bills incorporating key tax proposals.Continue Reading
South Africa issues interpretation note on interest withholding tax
South African Revenue Service has published an interpretation note on withholding tax on interest payments.Continue Reading
Global minimum corporate tax rate should be 15 percent: US Treasury
The US Treasury expressed its belief that the international tax architecture must be stabilized, that the global playing field must be fair, and that we must create an environment in which countries work together to maintain our tax bases and ensure the global tax system is equitable.Continue Reading
South Africa issues tax guidance on royalty, interest withholding tax
Interpretation Note 115 relates to withholding tax on interest and Interpretation Note 116 relates to withholding tax on royalties.Continue Reading
New UN transfer pricing manual released
The Manual is focused on transfer pricing in a global environment, while it provides guidance on design principles and policy considerations. It also addresses the practical implementation of a transfer pricing regime in developing countries and shares examples of country practices from developing countries, such as Brazil, China, India, Kenya, Mexico, and South Africa.Continue Reading
South Africa tax authority building APA legislative framework
Comments must be received by December 18.Continue Reading
South Africa consulting on rule to limit interest expense deduction
The Budget proposes to restrict net interest expense deductions to 30% of earnings for assessment years starting January 1, 2021.
Mutual Agreement Procedure Statistics Published for 2017
The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.
According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.Continue Reading
OECD Transfer Pricing Profiles for 7 More Countries Published
The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa, and Turkey. The OECD has also updated the information contained in Singapore’s profile.Continue Reading
Quantera Global, Africa Transfer Pricing Now Allies
Transfer pricing advisory firm Quantera Global has announced its strategic partnership with Africa Transfer Pricing, a professional services firm specializing in transfer pricing in South Africa.Continue Reading
SARS to Revive Large Business Unit
The South African Revenue Service (SARS) is re-establishing the Large Business Unit to ensure that the unit is responsive to the challenges currently being faced by SARS.Continue Reading
Switzerland Adopts Dispatch on BEPS Convention
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).Â
The Swiss Federal Council on Wednesday adopted the dispatch on the OECD’s Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading
Mutual Agreement Procedure Guide Issued by SARS
South Africa’s tax authority on July 25 published general guidance on the mutual agreement procedure (MAP) framework incorporated in tax treaties to resolve disputes.Continue Reading
Taxpayer Input Sought on Fresh Round of MAP Peer Reviews
The OECD is seeking taxpayers’ input for the sixth round of base erosion and profit shifting (BEPS) Action 14 Stage 1 peer reviews of eight new jurisdictions.Continue Reading
South Africa’s 2018 Budget: Unpacking International Tax Measures
By Ahmed Jooma (Independent Tax, Legal, and Public Policy Consultant)
On February 21, 2018, South Africa’s Finance Minister, Malusi Gigaba, presented the country’s National Budget, which will be tougher on the populace than on multinational corporations. Most of the tax changes that will affect cross-border transactions are of a technical nature. A continued focus on base erosion and profit shifting is expected to assist in arresting the deteriorating fiscal environment. This is further exacerbated by pressure to maintain a relatively low corporate tax rate in the face of tax competition.
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New South Africa Tax Guidance on Prohibition of Deductions for “Tainted” IP
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).Â
The South African Revenue Service has issued detailed guidance on the interpretation and application of section 23I of the Income Tax (IT) Act, which relates to the prohibition of deductions for “tainted” intellectual property (IP).Continue Reading