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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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| _version_ | 1867613226367188992 |
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| access_status_str | Open Access |
| author | Zimunhu, Auxillia |
| author2 | Emslie, Trevor |
| author_browse | Emslie, Trevor Zimunhu, Auxillia |
| author_facet | Emslie, Trevor Zimunhu, Auxillia |
| author_sort | Zimunhu, Auxillia |
| collection | Thesis |
| description | 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. |
| format | Thesis |
| id | oai:open.uct.ac.za:11427/43187 |
| institution | University of Cape Town (South Africa) |
| language | English eng |
| last_indexed | 2026-06-10T12:32:46.693Z |
| license_str | Not specified — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository |
| publishDate | 2026 |
| publishDateRange | 2026 |
| publishDateSort | 2026 |
| publisher | Department of Commercial Law |
| publisherStr | Department of Commercial Law |
| record_format | dspace |
| source_str | UCTD — University of Cape Town Open Access Repository |
| spelling | oai:open.uct.ac.za:11427/43187 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 Zimunhu, Auxillia Emslie, Trevor Commercial Law 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. 2026-05-06T09:27:36Z 2026-05-06T09:27:36Z 2010 2026-05-06T09:25:44Z Thesis / Dissertation Masters LLM http://hdl.handle.net/11427/43187 en eng application/pdf Department of Commercial Law Faculty of Law University of Cape Town |
| spellingShingle | Commercial Law Zimunhu, Auxillia 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 |
| thesis_degree_str | Master's |
| title | 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 |
| title_full | 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 |
| title_fullStr | 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 |
| title_full_unstemmed | 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 |
| title_short | 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 |
| title_sort | 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 |
| topic | Commercial Law |
| url | http://hdl.handle.net/11427/43187 |
| work_keys_str_mv | AT zimunhuauxillia transferpricinginsouthafricaacomparativeanalysisbetweensouthafricaandmoreadvancedjurisdictionsnamelytheunitedkingdomandtheunitedstatesofamerica |