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Transfer pricing in South Africa: An arm’s length principle case

Transfer pricing in South Africa: An arm’s length principle case

by Pieter van der Zwan | Sep 15, 2024 | Corporate and business tax

There have been few transfer pricing-related tax cases in South Africa. They mainly dealt with technicalities of section 31 of the Income Tax Act (‘the ITA’). However, a recent tax court case deals with applying the arm’s length principle, which is at the heart of...
Management fees: Is there a tax risk?

Management fees: Is there a tax risk?

by Pieter van der Zwan | Jul 18, 2022 | Corporate and business tax

Managers who advise and manage the affairs of others, for example, their investments or businesses, often charge management fees for those services. This is not unusual or out of the ordinary. In a tax context, certain arrangements that are labelled as management...

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