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Compliance focus for transfer pricing adjustments

Compliance focus for transfer pricing adjustments

19 January 2024 – The South African Revenue Service (SARS) has today published draft rule amendments for public comment with the view to facilitate transfer pricing adjustments.

The rule amendments under the Customs and Excise Act, 1964, (Act No91 of 1964) will provide clarity and certainty for multi-national enterprises on how to account for their transfer pricing adjustments on previous Customs declarations. This will ensure that they are compliant with their Customs obligations.

Price fluctuations of goods and services delivered by multinationals have a knock-on effect and impact the profits and, as a result, the tax liability of the multinationals. It is then the obligation of the multinational to adjust the transfer pricing payment retrospectively to ensure compliance.

The draft amendments have been published on the SARS website for public comment and announced on SARS social media. The Customs community is requested to participate in the process.

“This is another step to make it easy and simple for taxpayers and traders to comply voluntarily with their obligations,” said SARS Commissioner Mr Edward Kieswetter.

“Legislation allows the organisation to outline the rules and procedures that promote compliance in unambiguous terms and strengthen the tax and Customs eco-system that affects our stakeholders, nationally and internationally.”

For further information, please contact [email protected]

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