Cross-border transactions, especially those with connected persons, have always been under scrutiny in every aspect of business. This is no less true for taxation – SARS has always been attentive to dealings between connected persons and international trading.
This course aims to enable an understanding of the various tax laws that relate to transactions with foreign countries as well as those with connected persons.
This session will cover the following:
• Clarifying the concept of transfer pricing, connected persons and arm’s length values
• Transfer pricing adjustments to be made, amongst others, for income tax purposes
• Specific tax rules governing transactions with connected persons or transactions not made at arm’s length values:
o Loans with trusts
o Transactions with Controlled foreign companies
o Shareholder loans
o Fringe benefits
o Capital gains taxes
o Value shifting arrangements
o VAT rules for transactions with connected persons
• This course will also include an overview of the OECD’s models and suggestions on transfer pricing, and how SARS could approach making adjustments based on it
Taxpayers and entities that have dealings with connected persons, auditors and advisors might benefit from this course.
