The South African Revenue Service (SARS) has released Interpretation Note 128 – Definition of "Associated Enterprise" in Section 31 of the Income Tax Act, which contains transfer pricing rules. As provided in Section 31, "associated enterprise" means an associated enterprise as contemplated in Article 9 of the Model Tax Convention on Income and on Capital of the OECD. Article 9 describes two enterprises as being "associated enterprises" where: an enterprise of a Contracting State participates directly or indirectly in the management, control, or capital of an enterprise of the other Contracting State; or the same persons participate directly or indirectly...