The South African Revenue Services (SARS) has announced the release of Interpretation Note 127 – Determination of the Taxable income of Certain Persons from International Transactions: Intra-Group Loans, which provides guidance on how SARS will determine arm's length pricing for intra-group loans. The Note also provides guidance on the consequences for a taxpayer if the amount of debt, the cost of debt, or both are not at arm's length. --- Transfer pricing: Intra-Group Loans Tshwane, 17 JANUARY 2023 – The South African Revenue Service (SARS) has today released an interpretation note titled " DETERMINATION OF THE TAXABLE INCOME OF CERTAIN...