SARS Consulting on Draft Notices for Bilateral APA Pilot Program

The South African Revenue Service (SARS) has released a series of draft notices for public comment concerning bilateral advance pricing agreements (APAs) under a tax treaty (double taxation agreement). The framework for South Africa's APA program was introduced by the Tax Administration Laws Amendment Act 2023. The draft notices have been prepared for an initial pilot phase of the APA program, which is currently planned to only accept bilateral APA applications. The draft notices include:

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