Recent Developments in Transfer Pricing and Thin Capitalization

Journal
Lermer, D.
South Africa
International Transfer Pricing Journal 2011 (Volume 18), No. 2
Format/Price
JournalUSD 45

South African income tax provisions dealing with transfer pricing and thin capitalization were recently completely overhauled by the introduction of new transfer pricing and thin capitalization legislation as part of the 2010 Taxation Laws Amendment Act. This article discusses the current rules and some of the practical issues encountered upon assessment under the current rules, and provides an overview of the new rules.