South Africa's First Transfer Pricing Judgment
From the desk of Prof Dr Daniel N. Erasmus (Convenor of Postgraduate Programmes in Transfer Pricing in International Taxation).
First published on www.TaxRiskManagement.com
THE JUDGMENT WAS PUBLISHED BY THE SOUTH AFRICAN REVENUE SERVICE (SARS): DOWNLOAD IT HERE>>>
Entering into a trial is time-intensive and expensive. Our primary goal is to minimise such risks for Multinationals and Revenue Services by promoting proactive measures instead of relying on reactive responses.
The Middlesex University postgraduate programmes in Transfer Pricing and International Taxation deal with these topics extensively and have been designed for professionals who consult with and/ or are employed by multinationals and revenue authorities globally.
Transfer pricing is critical, especially when ensuring compliance with local tax regulations. The case of ABD Limited vs. The Commissioner for the South African Revenue Service (SARS) sheds light on the complexities and challenges surrounding transfer pricing practices in South Africa. This matter highlights the potential pitfalls for multinational companies and demonstrates the vital role of expert legal teams, such as TRM, in navigating these challenges successfully.
The Importance of the Case
Transfer pricing, the practice of setting prices for transactions between companies within the same corporate group, is crucial for tax purposes. It ensures that transactions with foreign subsidiaries are priced as if they were conducted between unrelated parties, maintaining fairness and preventing tax evasion. The ABD Limited case raises unique questions about transfer pricing, especially concerning the royalties for intellectual property rights and how they should be calculated to comply with South Africa’s tax laws.
TRM’s Role
This significant case underscores the expertise and effectiveness of TaxRiskManagement.com’s team. Specializing in transfer pricing disputes, we provided unparalleled guidance through this complex tax litigation process, demonstrating our deep understanding of South African tax laws and international transfer pricing principles. The strategic approach and meticulous preparation were instrumental in challenging SARS’s increased assessment based on the arm’s length principle—a cornerstone of transfer pricing regulations.
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LEARN MORE
These topics are dealt with in depth in the following Postgraduate Programmes offered by Middlesex University in partnership with the Academy of Tax Law and Informa Connect:
Postgraduate Programmes in Transfer Pricing:
APPLICATIONS NOW BEING ACCEPTED (Closes End of March 2024)
Postgraduate Programmes in International Taxation:
APPLICATIONS NOW BEING ACCEPTED (Closes End of March 2024)
Have some questions about the programmes?
Please don't hesitate to contact our Education Consultant, Ben Ellis, at [email protected] or call us on?+44(0)2080522710.