Browsing by Subject "Transfer pricing"
Now showing items 1-9 of 9
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Addressing challenges facing SARS relating to the application of transfer pricing in business restructurings
(North-West University, 2012)Multinational enterprises have been widely accused of using aggressive tax planning schemes to avoid paying tax all over the world. The purpose of this study is to analyse the methods used by multinational enterprises in ... -
Alternatives for the treatment of secondary transfer pricing adjustments in South Africa
(2014)Deviations from arm’s length prices (prices charged between independent persons) charged between connected cross-border companies are corrected by primary transfer pricing adjustments, effected by the tax authorities of a ... -
An analysis of the weaknesses in transfer pricing legislation pertaining to intellectual property
(2014)On 8 June 2012, National Treasury amended Regulation 10(1) (c) of the Exchange Control Regulations to specifically include intellectual property. In so doing, all companies wishing to dispace intellectual property to an ... -
A critical analysis of SARS' implementation of Advance Pricing Agreements
(North-West University (South Africa), 2022)Though the concept of transfer pricing has been in existence for over a century, it continues to evolve over time while remaining a topical issue globally. The increase in cross-border transactions by multinational ... -
An evaluation of transfer pricing provisions for financial assistance granted by a foreigner to a resident
(North-West University (South Africa), 2020)Transfer pricing rules are anti-avoidance measures that are governed by section 31 of the South African Income Tax Act No. 58 of 1962 (Income Tax Act). Section 31(6) of the Income Tax Act provides an exemption (subject to ... -
The regulation of retroactive transfer pricing adjustments and valuation of imported goods under the Customs and Excise Act 91 of 1964
(North-West University (South Africa)., 2020)Retroactive transfer pricing adjustment is defined as the adjustment of prices of goods sold within the MNEs in accordance with its transfer pricing policy. Retroactive transfer pricing adjustment is usually performed ... -
The relationship between transfer pricing adjustments and withholding tax on interest in South Africa
(North-West University (South Africa), 2020)In response to base erosion and profit shifting activities, section 31 of the Act was enacted to prevent profit shifting and base erosion brought about by the manipulation of cross-border transfer pricing practices carried ... -
Tax Planning Using Interest An Organised Chaos for Those Interested
(PER/PELJ, 2022)Taxation of interest is one of the most complex areas of tax in South Africa. Various provisions apply to interest, with some regulating the inclusion of interest in gross income, others allowing for the deductibility of ... -
The transfer pricing implications of hard-to-value intangibles : challenges and recommendations
(North-West University (South Africa) , Potchefstroom Campus, 2016)It has been noted with concern that multinational companies (MNC’s) have been engaging in base erosion and profit shifting that has resulted in the significant loss of tax revenue. Developing countries are the most affected ...