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.
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Can taxpayers lose by challenging SARS? The hidden risks in transfer pricing disputes
Taxpayers challenging assessments in transfer pricing disputes face hidden risks, including the rare possibility that the Tax Court could consider increasing an assessment.
Precedent-setting case highlights legal hurdles in transfer pricing disputes
The tax dispute between ABD and SARS highlights the complexity of IP royalty pricing and the importance of expert testimony in transfer pricing audits.
