Transfer Pricing Update Webinar
Globally, tax authorities are placing a significant focus on transfer pricing and the South African Revenue Service (SARS) is no exception.
It is therefore essential for all businesses transacting cross-border with related parties to stay up to date on the latest developments in the transfer pricing landscape. This webinar has been designed to create awareness and to keep you informed so that you can plan accordingly and manage and mitigate the potential tax risks.
Outline of the webinar:
Transfer Pricing Controversy
Transfer pricing disputes arise where a tax authority is of the opinion that a taxpayer’s cross-border transactions with related parties do not adhere to the “arm’s length” principle. The enquiry process involves the tax authority gathering information in order to determine whether the transfer pricing applied results in the local entity earning or paying an arm’s length price. If a business cannot successfully defend its pricing, this can lead to costly transfer pricing adjustments, which increase the amount of profits taxed in that country – resulting in double taxation, if those profits have been taxed elsewhere.
During this session we will discuss our latest experience in transfer pricing disputes and the role of audit readiness in the controversy lifecycle.
Financial Assistance
The pricing of intra-group loans and testing a local borrower’s debt capacity to ensure that it is not thinly capitalised are increasingly areas of focus for SARS. During this session we will provide a refresher on what is required from taxpayers with regards to cross-border lending transactions with related parties.
Transfer Pricing Developments in Other Countries NEW!
Significant tax reforms in Eswatini were gazetted in October 2023 and the key amendments, contained in the Eswatini Income Tax (Amendment) Act, 2023, including transfer pricing specific guidance came into force from 1 July 2024. Furthermore, during September 2024, HMRC released new Guidelines for Compliance, with the aim of providing UK businesses within the scope of UK transfer pricing rules with approaches to meet HMRC’s expectations for transfer pricing compliance in the UK, and to help businesses manage their potential UK transfer pricing risk as well as common areas that require transfer pricing scrutiny.
In this session we will discuss the notable developments in these countries, among others.
General Update on Other Transfer Pricing Developments
This session will provide a high-level update on various other transfer pricing related developments, such as the status of Advance Pricing Agreements in South Africa, the implications in practice of the “associated enterprise” definition incorporated into section 31 of the Income Tax Act for tax years commencing on or after 1 January 2023, Country-by-Country Reporting in light of the Global Minimum Tax Act, 2024, and developments regarding the OECD’s Amount B of Pillar One.
CPD - 2 hours