Arcotia Hatsidimitris - International Tax Dialogue

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92 – ANNEX B Financial Interest Insurance Other (specify) Other Reimbursement of expenses Cost sharing / cost contribution arrangements Employment costs for expatriate employees Other (specify) Total Value of transactions with non-resident related parties 8. The South African Revenue Service recognises the transfer pricing methods endorsed by the Organisation for Economic Development and Co-operation (OECD) in its Guidelines on Transfer Pricing for Multinational Enterprises and <strong>Tax</strong> Administrations (1995), the OECD Guidelines. These methods are outlined in Practice Note 7 issued on 6 August 1999. Please specify the transaction value for each of the transactions identified above, against each of the methods used to set or test the appropriateness of the pricing policy adopted. If more than one method was used please provide further details of such methods used and allocate the value against the primary method used. Please note that the total value of transactions should equal the total from the above table. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
ANNEX B – 93 Method Comparable Uncontrolled price (CUP) Received from non-resident related parties Supplied to non-resident related parties. Resale Price Method (RP) Cost Plus Method (CP) Transactional Net Margin Method (TNMM) Transactional Profit Split Method (TPSM) Other method (specify) Not tested Total Value of transactions 9. Has the company provided any goods or services (including the provision of financial assistance) to a non-resident related party for no consideration? If so, please provide details 10. Have any of the transactions listed in above occurred with a non-resident related party which is tax resident in a tax haven or low tax country? If so, please provide details DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
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ITD Transfer Pricing Conference: Tr
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Dealing Effectively with the Challe
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5 a) Organizational set-up Challeng
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5 a) Organizational set-up Head Off
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5 a) Reorganisation in the future H
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5 a) Organizational set-up National
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5 b) Staffing, training and managin
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Transfer Pricing Learning Curve Pot
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EXAMPLE: Training of the staff - CR
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5 c) Staffing, training and managin
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THANK YOU marica.houska@porezna-upr
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Dealing Effectively with the Challe
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FOREWORD - 3 Foreword This report i
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ABBREVIATIONS - 7 Abbreviations ADR
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10 - EXECUTIVE SUMMARY the fact fin
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1. INTRODUCTION - 13 Chapter 1 Intr
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1. INTRODUCTION - 15 Against this b
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1. INTRODUCTION - 17 • The ease o
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2. SELECTING THE RIGHT CASES - 19 C
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2. SELECTING THE RIGHT CASES - 21 I
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2. SELECTING THE RIGHT CASES - 23 I
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2. SELECTING THE RIGHT CASES - 25 T
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2. SELECTING THE RIGHT CASES - 27 d
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2. SELECTING THE RIGHT CASES - 29 N
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32 - 3. GETTING OFF TO A GOOD START
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38 - 4. GOVERNANCE ARRANGEMENTS Get
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40 - 4. GOVERNANCE ARRANGEMENTS •
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Arcotia Hatsidimitris - International Tax Dialogue

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