Transfer Pricing - Audit Readiness

Date: Aug 25, 2026

CPD hours: 2 Hours

Time: 15:00 - 17:00

Event Type: Webinar

The session provides practical guidance on managing transfer pricing audits, from responding to SARS information requests and maintaining a constructive relationship to assessing outcomes and resolution options. It focuses on developing an effective strategy early, managing resources and information flow, and minimising costs and potential double-taxation consequences.

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Overview

The session will cover the typical steps of a transfer pricing audit and how to manage and strategise each step, from responding to the requests for information and building a positive relationship with SARS, to considering the possible outcomes of the audit. Dealing with a transfer pricing audit can build a good relationship with SARS or frustrate the relationship, it is important to ensure any relationship will ensure a smooth progress of the audit and keep doors open for meaningful resolution, whilst maintaining management of information flows and use of internal resources. Considering the end point is so important based on the relative strengths of the defence and supporting evidence.

Not all transfer pricing audits need to be settled with double taxation consequences, there are alternatives and it is important to understand the implications of all of these as early as possible in the audit to ensure the best strategy is adopted to minimise cost and resolve the matter efficiently.

Webinar Content

Dealing with SARS request for information and building the relationship – Carryn Alexander
Looking at strategy from the beginning, how strong is the defence and the cost benefit analysis of settlement – Karen Miller
Responding to the SARS Letter of Audit Findings and Finalisation of Audit Letter – reducing the scope to limit the dispute – Carryn Alexander
Determining the next steps for resolving the matter – the options available and when to engage – Karen Miller

Competencies Development

A list of competencies developed in this CPD:

Awareness of SARS powers in requesting information and legal position of when to respond
Awareness of the dispute resolution process and timings.
Awareness of the options available and how these work and when they can be implemented.

Presenters

Karen Miller

Is a tax practice consultant with over 20 years of experience in corporate tax across South Africa, Australia, and the UK. A recognised expert in transfer pricing and international tax, she has held senior leadership roles at SARS, EY, and Deloitte. Karen advises on transfer pricing controversy, dispute resolution, and OECD compliance, and is a regular presenter at industry events and a published author on tax matters.

Carryn Alexander

Is a Partner in the Tax Practice based in Cape Town, specialising in tax dispute resolution and tax advisory services for multinational enterprises across Africa. With extensive experience in corporate tax, transfer pricing, VAT, customs, and cross-border transactions, she advises clients on complex tax disputes, compliance, and risk management. Carryn is recognised as a Leading Individual in Tax Law by Best Lawyers 2026.