Overview

Understanding the arm’s length principle is fundamental to transfer pricing and remains the cornerstone of cross-border taxation. This webinar provides a clear and practical introduction to how the principle is applied within South Africa’s transfer pricing framework, referencing Article 9 of the OECD Model Tax Convention, Section 31 of the Income Tax Act, SARS Practice Note 7, and the recently issued Interpretation Note 128.

Participants explore how the arm’s length principle guides the pricing of intra-group transactions to ensure that related parties transact as independent parties would under comparable circumstances.

As one of the most scrutinised areas of taxation, transfer pricing demands both technical precision and commercial understanding. Designed for tax professionals, finance managers, and compliance officers engaged in multinational operations, this session equips attendees to evaluate, document, and defend transfer pricing outcomes. Through practical examples and case studies, the webinar builds a foundational understanding of transfer pricing methods, comparability analysis, and documentation requirements, while addressing the enterprise provisions introduced in 2023 and their implications for compliance with the arm’s length standard.

Webinar Content

• Legal Framework Driving the Arm’s Length Principle
• Transfer Pricing Methods and Their Application
• Essentials of Comparability Analysis
• Special Scenarios and Complex Transactions
• Compliance and Documentation Strategies

Competencies Developed

• Analytical Assessment: Evaluate whether controlled transactions meet the arm’s length standard and distinguish between controlled and uncontrolled dealings.
• Method Selection: Identify and apply the most appropriate transfer pricing method for various transaction types.
• Risk Awareness: Recognise common risk indicators that may trigger SARS reviews and understand typical adjustment scenarios.
• Documentation Proficiency: Determine when documentation is required and compile compliant files that substantiate arm’s length pricing.
• Regulatory Interpretation: Interpret definitions of connected persons and associated enterprises, applying the relevant provisions under Section 31.

Presenter

Nthabiseng Kobe

Nthabiseng is a registered Transfer Pricing Specialist [TPS(SA)] with the South African Institute of Taxation. She holds an Honours degree in Taxation from the University of Pretoria and brings over nine years of experience in transfer pricing consulting, gained at leading audit firms. In 2025, she founded Kobe Consulting, an independent advisory firm specialising in transfer pricing, partnering with companies to analyse cross-border transactions and deliver tailored, practical solutions that ensure regulatory compliance and effectively manage tax risk.

Nthabiseng also contributes as a subject matter expert to the Tax Faculty, sharing her expertise with fellow professionals and supporting their growth in the dynamic field of transfer pricing. A passionate writer, she uses her voice to share insights, reflections, and experiences that inspire both learning and personal development.

CPD

Attending this webinar and the successful completion of the online assessment will secure a certificate of completion for 2 hours of Tax CPD.

Event Investment

Free for Tax Accountant CPD subscribers and Practice Packages. Not a CPD subscriber yet? Click here to register now.

• Regular price:  R460.00
• Group booking discounts available when you register for a group.

Payments & Cancellations

• All payments must be made by EFT or by credit card, at least 3 working days before commencement of an event.
• Kindly note that should payment not be received 2 days after the event, legal action will be taken
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