On 10 December 2021, the South African Revenue Service (SARS) made an announcement for inviting public comments for a model and draft legislation regarding Advance Pricing Agreement (APA) system until the end of January 2022. The draft model is divided into 7 stages: pre-application, application, processing, negotiations, finalization, implementation and monitoring and termination, amendment and extension stage. On the other hand, draft legislation follows a discussion paper conducted in 2020 for the introduction of an advance pricing agreement system to improve dispute resolution and tax certainty with respect to transfer pricing. That draft paper warned that SARS would need to phase in the APA regime, given capacity constraints at SARS, beginning with bilateral APAs.