On 31 July 2023, the National Treasury of South Africa proposes a draft legislation to implement advance pricing agreement (APA) program. An APA program offers taxpayers an enhanced level of assurance when engaging in significant international transactions with transfer pricing considerations. The APA program aims to minimize the likelihood of double taxation by establishing pre-defined transfer pricing methods that find acceptance from both South Africa and its treaty partners. The proposed legislation includes the anticipated process, fees, and requirements.
However, some aspects will need further clarification and detail, which will be published in public notices. The due date for submitting written comments regarding the draft is 31 August 2023.
