Taxpayers should prove arm’s length in domestic intra-group transactions
March 16, 2011
Salman Shaheen TPW
A Johannesburg Tax Court decision suggests taxpayers should be able to prove the arm’s length nature of domestic, as well as cross-border, intra-group transactions.
The court ruled in favour of an undisclosed mining company (referred to as ABC) in its appeal against the South African Revenue Service’s (SARS) disallowance of marketing and management expenses.
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