Arm’s length standard – June 2015
Arm's Length Standard is a bulletin of transfer pricing developments written by Deloitte Tax professionals of the member firms of Deloitte. The newsletter covers global and local transfer pricing trends and developments, providing you with agile and expert insight into the world of transfer pricing.
Our latest edition of Deloitte's Transfer Pricing Arm's length standard takes a look at:
• Secondary Transfer Pricing adjustments – Article by Billy Joubert and Nereen Isaac
• Complexities of using African comparable companies – Article by Steven Breslin
• Is settlement worth the price of double taxation? - Article by Lynne October and Karen Miller
• Beyond Transfer Pricing Documentation – The Transfer Pricing life cycle – Article by Claudia da Costa
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Secondary Transfer Pricing Adjustments
A change to section 31 of the Income Tax Act which came into effect on 1 January 2015, introduced a new form of secondary adjustment mechanism. This article gives an overview of both primary and secondary adjustment considerations for multinationals operating in South Africa.
Complexities of using African Comparable Companies
Deloitte Africa recently completed a high level study of comparables for African companies included on Orbis, a detailed global company information database. The research was commissioned to ascertain a better understanding of the information available in relation to African companies on the database and to give insight into the challenges faced by companies to gain access to such limited information.
Is settlement worth the price of double taxation?
Transfer pricing is becoming one of the most costly audit experiences for Multinationals across the globe and South Africa is no different. The focus on Base Erosion and Profit Shifting has seen a global move to scrutinise and close down many legitimate tax planning scenarios. This article looks at the issues around the often long and drawn out settlement process and double taxation resolution for multinationals.
Beyond Transfer Pricing Documentation - The Transfer Pricing life cycle
The OECD's concrete focus on the tax planning activities of corporates has seen a transformation in the transfer pricing process to a standardised transfer pricing cycle. Traditionally the responsibility to plan, identify, appropriately price and document transfer pricing policies rested with the tax specialists within multinationals or external advisors, however the cycle has raised questions around how this is managed through the operational implementation and monitoring phases of the cycle.