Transfer Pricing 

Arm's Length Standard

The latest edition of the Arm’s Length Standard is now available for download. The publication contains various articles and key insights from our Deloitte Transfer Pricing Team.

Country-by-country reporting: South Africa frequently asked questions

With country-by-country reporting coming into effect on 1 January 2016 Deloitte addresses the 10 most frequently asked questions in this regard. Download the PDF to read the 10 most frequently asked questions addressed by Carla Van Der Merwe.

Financial ratio analysis for thin capitalisation purposes

SARS has indicated that it would consider various financial ratios for selecting potential thin capitalisation cases for audit. In this article we investigate whether the ratios used may differ according to different industries. Download the PDF to read Steven Breslin’s article.

Transfer pricing disputes on the rise

The growing importance of transfer pricing in South Africa is clearly demonstrated by the vast amount of transfer pricing audits currently under investigation. This article will explain the process to be followed once an assessment has been received from SARS and the taxpayer’s perspective regarding this process. Download the PDF to read Michiel Els’ overview on Transfer pricing disputes on the rise.

Transfer pricing: An overwhelming compliance burden for taxpayers

Taxpayers were burdened with two significant new transfer pricing compliance developments during 2016. Firstly, country-by-country reporting was introduced with effect from 1 January. Secondly, detailed record retention rules for transfer pricing were introduced with effect from 1 October. Accordingly, Deloitte has discussed insights into this and future developments. Download the PDF to read Billy Joubert’s insights on the two new transfer pricing compliance developments.

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