The Taxation Laws Amendment Act of 2010 has introduced new transfer pricing (TP) rules. Sec. 31 of the Income Tax Act of 1962 has been repealed and replaced. According to an explanatory memorandum issued by the South African Revenue Service (SARS), the main reason for introducing new TP rules is to further align the Income Tax Act with Art. 9 of the OECD and UN Model Tax Conventions. This is in view of the fact that: -   the current wording focuses on separate transactions, as opposed to overall arrangements driven by an overarching profit objective; -   the current...