South Africa publishes draft tax law on advance pricing agreement

The South African Revenue Service is seeking stakeholders’ comments on a draft tax law implementing a new advance pricing agreement (APA) program.

The 2023 Draft Tax Administration Laws Amendment Bill seeks to incorporate an APA program in Part 1A of the Income Tax Act, 1962. The APA program is aimed at promoting tax certainty and preventing or minimizing double taxation.

The draft tax law provides for key aspects of the APA program such as making an APA application, withdrawal or rejection of an APA application, processing and finalizing an APA, submission of compliance reports, and termination of an APA.

Comments on the draft tax law must be received by August 31.