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PWC Tax Alert: Fixed non-compliance penalties imposed on TP documentation

Thursday, 17 May 2018   (0 Comments)
Posted by: Author: PWC
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Author: PWC

The SA Revenue Service (“SARS”) has indicated that the failure by a SA-resident Tier 1 company to submit a Country-by-Country report (“CbCR”), Master file (“MF”) or Local file (“LF”) return within 12 months from the final day of the group’s “Ultimate Parent Entity’s” financial year end will be an instance of non-compliance that will, in terms of sections 210(1) and 211 of the SA Tax Administration Act (“the TAA”), attract a financial penalty of up to R16,000 per month. SA’s CbC regime applies to financial years of multinational groups commencing on or after 1 January 2016. This means that the first CbCR, MF and LF returns are due to be submitted throughout the course of 2018. 

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