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How to survive a transfer pricing audit in South Africa

March 14, 2008

TP Week correspondent Jacques Van Rhyn, of PricewaterhouseCoopers, explains the environment for transfer pricing audits in South Africa

Depending on the facts applicable to each individual case, the South African Revenue Services (SARS) intends to follow the general guidelines for transfer pricing in South Africa, as set out in Practice Note 7 of the South African Income Tax Act No 58 of 1962 (Practice Note 7), when conducting a transfer pricing audit. Disclosure requirements, has become much more, stricter since the change in the requirements for disclosure and documentation in 2004 according to Practice Note 7 and the addendum to Practice Note 7.

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