23 11 2017
SARS recently announced that the Country-by-Country Reporting (“CbCr”) requirements are effective for financial years commencing on or after 1 January 2016. It must be noted that these requirements not only impact SA-resident parent companies, but also foreign-held SA-resident companies which may be required to submit CbCr in SA.
20 11 2017
The transfer pricing regime in the Income Tax Act, 58 of 1962, is regulated by section 31 of that Act. It in essence requires that cross-border transactions be entered into on an arm’s length basis where connected persons transact with one another. The obvious mischief sought to be countered is for connected persons to charge fees between one another to ensure that the party in the most tax beneficial regime is more profitable than the taxpayer in the more onerous tax jurisdiction.