Transfer Pricing: Practical Application of the Arm's Length Principle
Duration: 2 hours
Price: R195.00
Transfer Pricing: Practical Application of the Arm's Length Principle
Presenters : Nthabiseng Kobe
Overview
Understanding the arm’s length principle is fundamental to transfer pricing and remains the cornerstone of cross-border taxation. This video 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 video 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.
Video 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.
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