Browsing by Subject "Arm’s length"
Now showing items 1-2 of 2
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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 ... -
Thin capitalisation : an analysis of the application of the amended section 31(3) of the Income Tax Act no. 58 of 1962
(North-West University (South Africa), Vaal Triangle Campus, 2015)The current Income Tax legislation, in relation to thin capitalisation, requires South African-based entities to transact at an arm’s length basis. This is in accordance with the Draft Interpretation Note issued by the ...