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Retrospective country-by-country reporting and transfer pricing documentation requirements

Wednesday, 16 August 2017   (0 Comments)
Posted by: Author: Robyn Kantor
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Author: Robyn Kantor (ENSafrica)

South Africans who think that their tax burden is going to decrease because country-by-country (“CbC”) reporting does not apply to their company should think again!

In addition to the recently released draft notice requiring the submission of CbC reports, master file and local file returns, the South African Revenue Service (“SARS”) has recently issued the External Business Requirements Specification (“BRS”) document, setting out CbC and Financial Data Reporting (“FDR”) requirements.

South Africa’s master file and local file requirements are in line with the Organisation for Economic Cooperation and Development’s (“OECD’s”) requirements and South African taxpayers will now be obliged to submit transfer pricing-related returns.

The filing obligation detailed in the draft notice appears to apply retrospectively for years commencing on or after 1 January 2016. Consequently, qualifying taxpayers who have December year-ends may be expected to submit not only their first CbC report, but also master file and local file returns by 31 December 2017.

Even though these transfer pricing returns may not form part of the annual income tax return, it is probable that the due dates for all the returns (CbC reports, master file and local file returns) will coincide.

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