There are frequently reports of billions of rand leaving the SA tax net due to transfer pricing abuses. The narrative is broadly that SA multinational companies are shipping profits abroad to related parties situated in foreign jurisdictions (often tax havens) in contravention of the country’s transfer pricing rules. In terms of SA’s transfer pricing rules, where related parties in different jurisdictions provide intellectual property, goods, services or finance to each other they need to comply with the arm’s-length test. This means the pricing of such products should be comparable to what the party would charge an unrelated entity. The Organisation for Economic Co-operation and Development (OECD) has, over the years, come up with five methodologies to test whether transactions between related parties comply with the arm’s-length test. These methods are accepted and used by all OECD member states, as well as many nonmember states such as SA. Although there is no fixed hierarchy of ...

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