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Transfer pricing in South Africa: a comparative analysis between South Africa and more advanced jurisdictions, namely the United Kingdom and the United States of America
Transfer pricing is one of the most important yet controversial aspects of international tax in the last decade. South Africa is one of the few African countries which has set out regulations to deal with this issue yet undoubtedly the scope of application of these transfer pricing regulations is un...
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| Format: | Thesis |
| Language: | English English |
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Department of Commercial Law
2026
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| Summary: | Transfer pricing is one of the most important yet controversial aspects of international tax in the last decade. South Africa is one of the few African countries which has set out regulations to deal with this issue yet undoubtedly the scope of application of these transfer pricing regulations is unsatisfactory especially in the age of globalization and the rise of multinational corporations which are driving this globalisation. The legislation set out in section 31 of the Income Tax Act number 58 of 1962 lacks clarity and precision like the legislation set out in more advanced jurisdictions such as the United Kingdom and the United States of America. South Africa has not yet developed transfer pricing safeguards such as precise legislation on penalties, advanced pricing agreements, cost sharing agreements and transfer pricing regulations in the face of a recession. In essence this study seeks to establish how far transfer pricing legislation in South Africa has keep abreast with international standards put forth by other jurisdictions. |
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