The South African Revenue Service (SARS) has open consultation for a model and draft legislation for an advance pricing agreement system.
This follows a discussion paper conducted in 2020 for the introduction of an advance pricing agreement system to improve dispute resolution and tax certainty with respect to transfer pricing.
Currently, South Africa has an advance tax ruling system. This system does not cater for transfer pricing and cannot be used to request an advance pricing agreement.
The proposed model is currently divided into 7 stages: Pre-application, application, processing, negotiations, finalization, implementation and monitoring and termination, amendment and extension stage.
Comments are open until 31 January 2022.
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