SAICA comments on a suggested Draft Interpretation Note on Transfer Pricing to replace Practice Note 7

The submission contains SAICA’s suggestions of items/topics that should be included in an Interpretation Note on Transfer Pricing to replace Practice Note 7. The topics/items include include, inter alia, various domestic legislative issues for consideration, areas where there is divergence by SARS from the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and matters relating to dispute resolution processes.