The purpose of the workshop is to provide delegates with a broad overview of the South African transfer pricing rules and the practical application there
The course material is designed to be interactive and to deal with practical examples raised during the workshop as far as possible within the timeframe.
The following broad topics will be covered:
- The basic international tax concepts to consider when dealing with foreign group entities:
- Residence (effective management)
- SA controlled foreign company rules
- Substance
- Brief overview of SA headquarter regime
- Background and development of SA transfer pricing rules
- Previous versus new transfer pricing legislation and application thereof
- Arm's length principle
- Transfer pricing methods
- CUP method
- Resale Price method
- Cost plus method
- Transactional net margin method
- Profit split method
- Examples of transactions that would be subject to transfer pricing
- Basic format of transfer pricing documentation
- Functional and risk analysis
- Economic analysis - Benchmarking and use of comparables in support of pricing
- Basic treatment of intangibles
- Transfer pricing adjustments
- Interaction with exchange control and customs
- Practical case studies
Who should attend?
Any person involved with cross border international company transactions within multi-nationals or in an advisory capacity.
Date: 19 April 2013
Time: 09:00 - 13:00
Venue: BDO House, 22 Wellington Rd, Parktown, Johannesburg
Cost: R3000 (SAICA members R2700)
Date: 26 April 2013
Time: 09:00 - 13:00
Venue: The Boulevard Office Park, Searle St, Woodstock, Cape Town
Cost: R3000 (SAICA members R2700)
Date: 24 May 2013
Time: 09:00 - 13:00
Venue: The Boulevard Office Park, Searle St, Woodstock, Cape Town
Cost: R3000 (SAICA members R2700)
Date: 31 May 2013
Time: 09:00 - 13:00
Venue: BDO House, 22 Wellington Rd, Parktown, Johannesburg
Cost: R3000 (SAICA members R2700)