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South Africa - Recent Developments in Transfer Pricing and Thin Capitalization

South Africa
D. Lermer
International Transfer Pricing Journal, 2011 (Volume 18), No 2
21 February 2011
South African income tax provisions dealing with transfer pricing and thin capitalization were recently completely overhauled by the introduction of new transfer pricing and thin capitalization legislation as part of the 2010 Taxation Laws Amendment Act. This article discusses the current rules and some of the practical issues encountered upon assessment under the current rules, and provides an overview of the new rules.
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