South Africa: Increased transfer pricing scrutiny

A discussion on transfer pricing trends in South Africa

A discussion on transfer pricing trends in South Africa

The number of transfer pricing adjustments imposed by the South African Revenue Service (SARS) has increased significantly over the last couple of years.

In addition, when SARS applies the results of a transfer pricing benchmarking study during the course of an audit, it usually selects the median as the arm’s length margin or price—without necessarily demonstrating that based on the relevant facts and circumstances the median margin or price is actually arm’s length, versus some other margin or price within the range.

Read a September 2022 report [PDF 251 KB] prepared by the KPMG member firm in South Africa that discusses these and other trends in transfer pricing in South Africa


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