FAQ: What are the defined categories of Master File documents to be uploaded?

According to Annexure I to Chapter V of the Transfer pricing documentation, the following information should be included in the Master File:- Organisational Structure (Organogram) Description of MNE Business or Businesses MNE Intangibles (as defined in Chapter VI of these Guidelines) MNE Intercompany Financial Activities MNE Financial and Tax positions

FAQ: Must members of MNE Groups notify SARS of who will file?

Yes, Article 3 of the CbC Regulations stipulates the notification requirements as follows: – Any entity that is a member of an MNE Group and is resident in South Africa for tax purposes must notify SARS if it is the UPE. If the entity is not the UPE it must notify SARS of the identity […]

FAQ: What format must the return be in?

The return must be in the format specified in the Business Requirements Specification (BRS): Country-by-Country and Financial Data Reporting. The BRS can be found on the SARS website.