South Africa: Transfer Pricing

This issue of ENS' tax in brief provides a comprehensive snapshot of recent South African tax developments, including significant High Court judgments on SARS appeals and enforcement orders, new SARS publications on documentary proof requirements and the Advance Pricing Agreement programme, and multiple customs and excise tariff amendments affecting various imported goods. The brief also covers important international developments from the OECD regarding the Global Minimum Tax implementation and corporate t

This comprehensive update covers significant tax and regulatory developments across 30 African jurisdictions during mid-2026, including Angola's new oil block incentives and unified Personal Income Tax Code, Botswana's major tax rate increases and transfer pricing regulations, Kenya's Finance Act 2026 with mortgage interest relief expansion, Nigeria's implementation of the unified Taxpayer Identification system and presumptive tax regime, and Rwanda's new transfer pricing rules framework. The bulletin exami

The African Tax Administration Forum and OECD have concluded transfer pricing workshops for Francophone tax officials, while multiple African nations implement significant tax reforms including VAT changes, e-invoicing requirements, and new compliance measures. From Kenya's reduced petroleum VAT rates to Liberia's comprehensive tax amendments and Uganda's proposed alternative minimum tax, these developments reflect a continent-wide effort to modernize tax administration and enhance revenue collection.

AFRICA: Suggested approach to drafting transfer pricing legislation updated by ATAF...

A recent scenario involved a South African company structuring an intellectual property (IP) licensing agreement with an offshore partner.

Below, please find issue 137 of ENS' Tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa has recognised the importance of offering taxpayers greater certainty and predictability in their tax affairs through the recently proposed Advance Pricing Agreement ("APA") programme.

Normally, a sales agent and a buy-sell distributor would not be regarded as comparable owing to the differences in functions, assets and risks relevant to each party.

The Economic Community of West African States ("ECOWAS") announced on 7 July 2023 that it has adopted a new VAT directive (C/DIR.3/07/2023)...