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Transfer Pricing in South Africa: Key Developments Shaping 2025–2026

Latest NewsJune 1, 2026693Views 0Likes 0Comments

South Africa’s transfer pricing landscape has shifted sharply in 2025–2026, driven by aggressive SARS litigation, tightened procedural limits on SARS, and a renewed focus on substance, people functions, and offshore IP structures. The three most important developments come from major court cases and SARS’s evolving enforcement posture. 1. SARS v SC (Pty) Ltd (Tax Court,…

Absa v SARS: Landmark Constitutional Court Ruling on Tax Avoidance

Latest NewsMay 12, 2026672Views 0Likes 0Comments

The most recent major tax avoidance case is the Absa Bank Ltd & United Towers v SARS Constitutional Court judgment delivered on 22 April 2026. This is the most current and significant tax avoidance ruling in South Africa. What the Court decided Ignorance is not a defence against the application of the General Anti-Avoidance Rule…

International Court Cases with Key Takeaways for South African

Latest News, Transfer Pricing CasesApril 17, 2025637Views 0Likes 0Comments

Case Information: Court: Cour Administrative d’Appel de Paris, 9th Chamber Case Number: 23PA01130 Applicant: SAS Roger Vivier Paris Defendant: French Ministry for the Economy, Finance, and Industrial and Digital Sovereignty Judgment Date: 13 December 2024 Background SAS Roger Vivier Paris (RVP) operates a luxury goods boutique in Paris, distributing Roger Vivier-branded footwear and accessories. The…

Global Minimum Tax

Latest NewsApril 17, 2025393Views 0Likes 0Comments

The Global Minimum Tax Act, 2024, 51830 dated 24 December 2024 has been officially gazetted in South Africa with retrospective effect to apply for tax years starting from 1 January 2024. This Act aligns with the OECD’s Pillar Two framework under the Base Erosion and Profit Shifting (BEPS) project. The law adopts the GloBE (Global…

What The New 7C Amendments in Effect Say – Effective 1 January 2025

Latest NewsApril 17, 20251KViews 0Likes 0Comments

If a cross border loan made to a trust by an individual or a company connected to that individual is considered an affected transaction* and subject to transfer pricing provisions contained in section 31: Section 7C will not apply to the market related rate of interest determined under section 31. However section 7C will still…

10 Years Transfer Pricing Sub-Committee

Latest NewsFebruary 16, 2023204Views 0Likes 0Comments

Thank you SAICA and members for this prestigious acknowledgement. It is truly an honour to be a part of such a leading professional organization that adds so much value on so many levels . SAICA has added depth to my professional career on a grand scale for which I could never say thank you enough.…

Timing Limitations

Latest NewsJune 25, 2019239Views 0Likes 0Comments

Transfer Pricing Timing Limitations - Country by Country Reporting. View our slides below for more information.

ALERT… The latest Transfer Pricing trend in Africa

Latest NewsJune 25, 2019246Views 0Likes 0Comments

The latest trend when it comes to inbound interest free loans into an entity in Africa from either a local or an offshore group company, is that numerous Tax Authorities across Africa are imputing an interest amount into the hands of the group company who is the borrower with a view to raising the withholding…

New Income Tax – Transfer Pricing Regulations – Zimbabwe May 2019

Latest NewsJune 3, 2019364Views 0Likes 0Comments

There are more onerous transfer pricing documentation requirement regulations for companies as has been unveiled by Finance Minister, Mthuli Ncube . This is in line with Ncube’s objective of protecting and broadening the tax base of Zimbabwe and prevent Base Erosion and Profit Shifting. Under Statutory Instrument 109 of 2019 published in the latest Government…

Recent Transfer Pricing Case in Zambia

Latest NewsJune 3, 2019555Views 0Likes 0Comments

NESTLE Zambia Trading Limited vs Zambia Revenue Authority [2018] TAT 03 (30 and 31 October 2018 and 28th March 2019) The Zambia Revenue Authority (the ZRA) performed a transfer pricing audit with respect to Nestlé Zambia’s operations on the basis that Nestlé Zambia had reported losses for the financial years 2010-2014. Nestlé Zambia had declared…

Greater transparency among Tax Authorities across the world

Latest NewsMay 13, 2019239Views 0Likes 0Comments

Have you considered these important international tax principles? The ramping-up of country-by-country (CbC) reporting to regulate transfer pricing and combat cross-border tax evasion, in terms of the Organization for Economic Co-Operation and Development’s (OECD) base erosion and profit shifting (BEPS) policies heralds a new tax landscape. It makes different demands of tax authorities worldwide and…

Recent Transfer Pricing Cases in Africa

Latest NewsMay 3, 2019264Views 0Likes 0Comments

South Africa: Crookes Brothers Limited v Commissioner for the South African Revenue Service (May 2018) Malawi: Eastern Produce (MW) V Malawi Revenue Authority (July 2018) Zambia: Nestle vs ZRA (March 2019) Ghana: Biersdorf GH Ltd and the Commissioner General(August 2018)