South Africa Releases Interpretation Note on Pricing of Intra-Group Loans

The South African Revenue Services (SARS) has announced the release of Interpretation Note 127 – Determination of the Taxable income of Certain Persons from International Transactions: Intra-Group Loans, which provides guidance on how SARS will determine arm's length pricing for intra-group loans. The Note also provides guidance on the consequences for a taxpayer if the amount of debt, the cost of debt, or both are not at arm's length.

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Transfer pricing: Intra-Group Loans

Tshwane, 17…