South Africa: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Africa Tax In Brief - 14 July 2026

This comprehensive update covers significant tax and regulatory developments across 30 African jurisdictions during mid-2026, including Angola's new oil block incentives and unified Personal Income Tax Code, Botswana's major tax rate increases and transfer pricing regulations, Kenya's Finance Act 2026 with mortgage interest relief expansion, Nigeria's implementation of the unified Taxpayer Identification system and presumptive tax regime, and Rwanda's new transfer pricing rules framework. The bulletin exami

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ENS

Africa Tax In Brief

The African Tax Administration Forum and OECD have concluded transfer pricing workshops for Francophone tax officials, while multiple African nations implement significant tax reforms including VAT changes, e-invoicing requirements, and new compliance measures. From Kenya's reduced petroleum VAT rates to Liberia's comprehensive tax amendments and Uganda's proposed alternative minimum tax, these developments reflect a continent-wide effort to modernize tax administration and enhance revenue collection.

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ENS

Tax In Brief | Issue 164 | 24 MARCH 2026

Issue 164 of ENS' tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa Tax

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ENS

Extending Boundaries: Adjustments To South African Exchange Control Limits And Powers

The Financial Surveillance Department of the South African Reserve Bank (“FinSurv”) recently published a suite of draft exchange control circulars for comment, giving effect to the Minister of Finance’s 2026 Budget Speech announcements...

South Africa Tax

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ENS

Can Taxpayers Lose By Challenging SARS? - The Hidden Risks In Transfer Pricing Disputes

South Africa Tax

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Webber Wentzel

Trusts In Focus – Succession Planning In South Africa

South Africa Tax

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ENS

Tax Focus: August/September 2025

South Africa Tax

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SNG Grant Thornton

Women Powering Progress Khanyisa Cingo-Ngandu

South Africa Tax

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SNG Grant Thornton

Trade Implications Of ITAC's 15% NEV Battery Tariff Proposal

South Africa Tax

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Andersen in South Africa

Africa Tax In Brief

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ENS

ENS Tax In Brief - Issue 146

South Africa Tax

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ENS

How SA Exports May Be Affected By New Tariffs Imposed By USA

South Africa International

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Andersen in South Africa

South Africa's Trade Infrastructure: A Wake-Up Call

South Africa Tax

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Andersen in South Africa

Africa Tax In Brief

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ENS

Information Regulator’s First Enforcement Notice For 2026

South Africa Privacy

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ENS

Intellectual Property Rights: Why Litigation Remains The Effective Enforcement Tool

South Africa IP

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Barnard Inc.

AI Tokens: The Hidden Commercial Risk In Enterprise AI Deals

South Africa Technology

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ENS

ENSign | Legal Bytes Over Coffee: Episode 3 | 2026 (Video)

South Africa Media & IT

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ENS

Payments First: Why The SARB Is Prioritising Digital Infrastructure Over A Retail CBDC

South Africa Finance

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ENS

Viewing The SARB's Exchange Control Revisions Through An IP Licensing Lens

A recent scenario involved a South African company structuring an intellectual property (IP) licensing agreement with an offshore partner.

South Africa IP

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Fairbridges

ENS Tax In Brief - Issue 137

Below, please find issue 137 of ENS' Tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa Tax

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ENS

ENS Tax In Brief - Issue 136

Below, please find issue 136 of ENS' Tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa Tax

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ENS

Decoding Transfer Pricing: The Commercialisation Of IP For Multinational Corporations

When companies operate globally, they often share goods and services within their own network of subsidiaries. The prices they set for these transactions are known as transfer pricing.

South Africa Tax

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Fairbridges

Tax Masterclass: Transfer Pricing (Video)

South Africa Tax

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ENS

VAT Treatment Of Electronic Services: South Africa's Proposed New Regime Released For Public Comment

South Africa Tax

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ENS

Tax Savvy: Understanding South Africa's Tax Regime For Foreign Enterprises

South Africa Tax

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Andersen in South Africa

Navigating Transfer Pricing Challenges In The Mining Sector

South Africa Tax

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ENS

Tax Disputes: Consideration Of Remedies Other Than Objection And Appeal

South Africa Tax

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SNG Grant Thornton

A Shift In South Africa's Approach On Transfer Pricing Disputes (ABD LIMITED V CSARS, TAX COURT, CASE NO IT 14302)

South Africa Tax

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SNG Grant Thornton

Providing Vested Rights In Respect Of Discretionary Trusts

South Africa Commercial

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

Transfer Pricing: Insights On Landmark Judgment

South Africa Tax

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Andersen in South Africa

Providing Vested Rights In Respect Of Discretionary Trusts

The rise of the discretionary family trust has long seemed inevitable. It appears to provide unparalleled commercial and fiscal flexibility to achieve multi-generational wealth transfer...

South Africa Commercial

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ENS

Africa Tax In Brief

Following the publication of the 2020 ATAF policy brief, the African Tax Administration Forum ("ATAF") on 4 April 2024 published a second policy brief for the taxation...

South Africa Tax

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ENS

Africa Tax In Brief

In order to address the effects of the 15% increase in fuel prices which came into effect on 3 February 2024, the following ad hoc tax changes have been announced through a public notice...

South Africa Tax

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ENS

Transfer Pricing: Insights On Landmark Judgment

The tax court, sitting in Johannesburg, was called upon to adjudicate a transfer pricing dispute between ABD Limited ("ABD"), a telecommunications company...

South Africa Tax

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Andersen in South Africa

Africa Tax In Brief

South Africa Tax

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ENS

Transfer Pricing: Getting The Basics Right

Normally, a sales agent and a buy-sell distributor would not be regarded as comparable owing to the differences in functions, assets and risks relevant to each party.

South Africa Tax

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ENS

Africa Tax In Brief

The Economic Community of West African States ("ECOWAS") announced on 7 July 2023 that it has adopted a new VAT directive (C/DIR.3/07/2023)...

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ENS

SARS Released The Draft Legislation On The Advance Pricing Agreements Programme

On a high level, Advance Pricing Agreements ("APA") allow multinational entities to enter into an agreement with one or more tax authorities were the taxpayer(s) and revenue...

South Africa Tax

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SNG Grant Thornton

ENSafrica Tax In Brief

This application concerns the eligibility of diesel refunds claimed by the Goedgevonden Joint Venture ("JV") in terms of section...

South Africa Tax

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ENS

Tax In Brief | Issue 103

South Africa Tax

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ENS

Tax Focus - May / June | 2023

South Africa Tax

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SNG Grant Thornton

Africa Tax In Brief

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ENS

Tax Focus - April Edition 2023

South Africa Tax

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SNG Grant Thornton

Value Chain Analysis – The Future Of Transfer Pricing

South Africa Tax

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ENS

Externalising IP?- What Do You Need To Know

South Africa Commercial

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ENS

Tax Updates - Regional Tax Publication, March 2023

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SNG Grant Thornton

What Is Inside The New Rwanda Tax Procedure Law?

South Africa Tax

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ENS

Preparation For A Transfer Pricing Audit: Are You Ready?

South Africa Tax

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ENS

The Untested Waters Of Transfer Pricing Disputes

South Africa Tax

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

SARS Issues Draft Interpretation Note On Intra-group Loans

South Africa Tax

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SNG Grant Thornton

Tax Guide 2022/23

South Africa Tax

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SNG Grant Thornton

Transfer Pricing, Thin Capitalisation And Intra-group Finance Arrangements – SARS Issues Promised Guidance In The Form Of Draft Interpretation Note

South Africa Tax

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ENS

Tax In Brief | Issue 78

South Africa Tax

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ENS

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Latest Videos

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Tax Masterclass: Transfer Pricing (Video)

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Webinar | Transfer Pricing Developments In Rwanda: What Does The Future Hold? (Video)

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Juristconsult NEW Webcast: "IS MAURITIUS READY FOR BEPS?" (Video Content)

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Juristconsult Chambers

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