Webinar date: 7 February 2022

Transfer pricing legislation and the international tax world continue to evolve and legislation in South Africa is no different.

We have seen a change to the definition of what constitutes an “affected transaction” which greatly widens the scope of South African Transfer Pricing legislation. SARS have issued a document setting out a Proposed Model for Establishing an Advance Pricing Arrangement and, in addition, are considering amendments specific to the tax treatment of companies that are considered to be excessively financed by way of debt. Internationally we have seen the OECD issue its Global Anti-Base Erosion rules which are designed to ensure that internationally active companies will be subject to a minimum effective taxation rate of at least 15% in all jurisdictions in which they operate. For any company operating cross border, or who are part of an international group, it is important to be aware of this changing environment.

This webinar covered:

  • Changes to the definition of “Affected Transaction” and what this means
  • Excessive debt financing and interest deductibility limitation rules
  •  OECD Pillar One and Pillar Two Global Anti-Base Erosion Rules

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