Transfer pricing is a key focus area for the South African Revenue Service (SARS), requiring multinational and local groups to ensure that all cross-border transactions between connected persons are conducted at arm’s length. Non-compliance can lead to significant tax adjustments, penalties, and reputational risk. Our consulting services help businesses design, document, and defend transfer pricing policies that meet South African and international standards.

Why It Matters

A sound transfer pricing strategy ensures compliance the Income Tax Act, prevents double taxation, and supports transparent profit allocation. It also enhances operational efficiency and reduces the risk of disputes with SARS.

Our Services

• Policy Design and Implementation: Development of tailored transfer pricing frameworks for goods, services, royalties, and financing transactions.
• Economic and Benchmarking Analysis: Functional and economic studies using reliable South African and global data to determine arm’s length pricing.
• Audit and Dispute Support: Assistance during SARS audits, including defense of transfer pricing positions and negotiation of settlements.
• Advance Pricing Agreements (APAs): Advisory and representation in negotiating APAs to achieve certainty and minimize future disputes.
• Operational Transfer Pricing: Integration of transfer pricing policies into financial systems and day-to-day operations.

Why Choose Us

• In-depth knowledge of South African tax law and SARS requirements.
• Proven experience across Africa and global markets.
• Multidisciplinary team.
• Data-driven, practical, and compliant solutions

Get in Touch

Ensure compliance, minimize risk, and enhance global tax efficiency.
Contact us today to learn how our South African transfer pricing experts can help your business achieve sustainable growth and regulatory confidence.