On 31 July 2020, the National Treasury published the 2020 Draft Taxation Laws Amendment Bill, which includes a proposed change to the definition of “affected transaction” for transfer pricing purposes. The proposed amended definition would be used to address situations when a tax benefit is indirectly derived by a South African resident as a result of its shareholding in a controlled foreign company (CFC). Public comments of the draft Law are invited until 31 August 2020. The proposed effective date of this amendment is 1 January 2021.