The South African Revenue Service (SARS) has published a discussion paper on the introduction of an Advance Pricing Agreement (APA) system in order to improve dispute resolution and tax certainty with respect to transfer pricing. SARs currently has an advance tax ruling system, although this does not cater for transfer pricing and cannot be used to request an advance pricing agreement or its equivalent.
The paper notes that although SARS is not ready to implement an APA system at this point…