Arcotia Hatsidimitris - International Tax Dialogue
Arcotia Hatsidimitris - International Tax Dialogue
Arcotia Hatsidimitris - International Tax Dialogue
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86 – ANNEX B<br />
6. The South African Revenue Service recognises the transfer pricing methods endorsed by the<br />
Organisation for Economic Development and Co-operation (OECD) in its Guidelines on<br />
Transfer Pricing for Multinational Enterprises and <strong>Tax</strong> Administrations (1995), the OECD<br />
Guidelines. These methods are outlined in Practice Note 7 issued on 6 August 1999. Please<br />
specify the transaction value for each of the transactions identified above, against each of the<br />
methods used to set or test the appropriateness of the pricing policy adopted. If more than one<br />
method was used please provide further details of such methods used and allocate the value<br />
against the primary method used. Please note that the total value of transactions should equal the<br />
total from the above table.<br />
Method<br />
Comparable Uncontrolled<br />
price (CUP)<br />
Received from non-resident<br />
related parties<br />
Supplied to non-resident<br />
related parties.<br />
Resale Price Method (RP)<br />
Cost Plus Method (CP)<br />
Transactional Net Margin<br />
Method (TNMM)<br />
Transactional Profit Split<br />
Method (TPSM)<br />
Other method (specify)<br />
Not tested<br />
Total Value of transactions<br />
7. Has the company provided any goods or services (including the provision of financial assistance) to<br />
a non-resident related party for no consideration?<br />
If so, please provide details<br />
8. Have any of the transactions listed in above occurred with a non-resident related party which is tax<br />
resident in a tax haven or low tax country?<br />
DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
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