Overview

More than a year has passed since the announcement that the South African transfer pricing rules would undergo a substantial redrafting process in order to align them with international best practice.

In the meantime, the initially envisaged effective date of the 1 October 2011 has come and gone and the third updated version of the new section 31 of the Income Tax Act 58 of 1962 has just been introduced by the Minister of Finance to Parliament in terms of the Taxation Laws Amendment Bill, 2011 (No. 19 of 2011), which if promulgated in its current form, will come into operation on 1 April 2012.

In this update, Field Fisher Waterhouse's Jens Brodbeck provides background to the redrafting process, details the latest Section 31 draft and thin capitalisation rules.

Click 'View Briefing' to read on.