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South Africa Issues Public Notice on Additional Transfer Pricing Documentation Requirements for Consultation

18 December 2015

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Proposed Changes

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South Africa

The South African Revenue Service (SARS) has issued a draft public notice for consultation on additional record keeping requirements for transfer pricing transactions. The requirements are based on the Master and Local File requirements of Action 13 of the OECD BEPS Project and would affect South African companies that have entered into potentially affected (related party) transactions and are a member of a group (50% equity or voting rights threshold) with consolidated South African revenue of ZAR 1 billion (~USD 65.7 million) or more. Some of the information to be kept includes: A description of the company's ownership structure; Details...