
SA closer to advance pricing regime, but thresholds threaten access
The new APA process aims to reduce disputes and double taxation, but practitioners say the entry bar is so high that few groups will qualify.

The new APA process aims to reduce disputes and double taxation, but practitioners say the entry bar is so high that few groups will qualify.

A wider interpretation of ‘party’ under GAAR means even commercially sound participants may face SARS’s scrutiny in multi-entity transactions.