• Danielle Geldenhuys

Africa Transfer Pricing Practice Guide

Updated: Apr 11


Wiesener, C. and Gosai, N. Africa transfer pricing practice guide. – LexisNexis, 2021– (Loose-leaf update).


Summary provided by the publisher:


“This publication demystifies transfer pricing from a South African perspective and provides a single source of commentary, case law, legislation and regulatory materials. Avail mid-December 2021.

The OECD BEPS initiative has caused many countries across the world to review and implement transfer pricing legislation. Multinationals are aware that there is an increasing need to pay attention to developments in this area going forward. While transfer pricing is well documented in most of the developed world, this is not the case in Africa. This publication explains transfer pricing related rules and regulations, addresses typical transfer pricing issues and highlights deviations from OECD rules.”


Table of contents:

  • Introduction and history

  • The arm's length principle

  • Legislation and supplementary guidance

  • Transfer pricing documentation requirements

  • Function, risk and asset analysis

  • Transfer pricing methodology

  • Comparability

  • Attribution of profits to permanent establishments

  • Specific transaction types

  • Non-compliance with the transfer pricing law and regulations

  • Transfer pricing audits

  • Controversy

  • Statutory accounting considerations

  • Appendices

  • Glossary

  • Section 31 of the Income Tax Act Tabulation

  • South African transfer pricing law and regulations

  • Summary SARS Practice Note No. 7


Price: R1,897.50 (print) excluding delivery, including VAT.


The book can be ordered from the Lexinfo Book Supply Service by sending an email to books@lexinfo.co.za


Date posted: 20 January 2022

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