Transfer Pricing webinar
Outline of the webinar:
1. Advance Pricing Agreements
The purpose of an advance pricing agreement (“APA”) with one or more revenue authorities is to provide taxpayers with tax certainty when entering into large cross-border transactions with related parties. Globally, multinational enterprises rely on APAs to avoid costly transfer pricing disputes with revenue authorities. In South Africa, the legislative framework for an APA system was introduced at the end of 2023 and SARS has now released draft regulations for the pilot phase of the APA programme for public comment.
We explore the latest developments with regards to the proposed APA programme in South Africa and unpack the new draft regulations, including eligibility to apply for an APA, the fees payable by an applicant, additional reasons that may lead to the rejection of an application for an APA, information to be included in a preliminary APA and guidelines for the implementation and operating of the APA system.
2. Residual Profit Split Arrangements
As value creation models become more integrated and collaborative across multinational groups, traditional pricing methods may not always capture the economic reality of intercompany transactions. Profit split arrangements are therefore gaining increased attention from tax authorities and taxpayers alike, particularly in scenarios involving shared value drivers, intangibles, the sharing of risks, and highly interdependent operations.
In this session, we unpack the practical application of the residual profit split method, discuss when it is most appropriate to use, and highlight key considerations for implementation. Our specialists also share insights into current trends, common challenges, and how organisations can align their transfer pricing policies with evolving regulatory expectations.
CPD hours: 2
Presenters:
Billy Joubert
Senior Associate Director
Deloitte Tax & Legal Transfer Pricing
bjoubert@deloitte.co.za
Philip Fouché
Senior Associate Director
Deloitte Tax & Legal Transfer Pricing
pfouche@deloitte.co.za