26/09/24

South Africa : The heart of transfer pricing tested for the first time in courts

The assessment followed an audit of ABD’s transfer pricing methodology by the South African Revenue Service (Sars). Experts believe this precedent-setting case provides a glimpse into how courts may approach transfer pricing cases in future.

It suggests a preference for “established and recognised” methods as opposed to “novel and untested approaches” to transfer pricing disputes, says Pieter van der Zwan, independent tax advisor and accounting specialist, in his analysis of the case.

The assessment followed an audit of ABD’s transfer pricing methodology by the South African Revenue Service (Sars). Experts believe this precedent-setting case provides a glimpse into how courts may approach transfer pricing cases in future.

It suggests a preference for “established and recognised” methods as opposed to “novel and untested approaches” to transfer pricing disputes, says Pieter van der Zwan, independent tax advisor and accounting specialist, in his analysis of the case.