Transfer pricing : an evaluation of section 31 of the Income Tax Act

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dc.contributor.advisorGutuza, Tracyen_ZA
dc.contributor.authorDean, Kirsty Annen_ZA
dc.date.accessioned2014-11-05T03:54:05Z
dc.date.available2014-11-05T03:54:05Z
dc.date.issued2014en_ZA
dc.descriptionIncludes bibliographical references.en_ZA
dc.description.abstractThe focus of this paper is on South Africa’s implementation and application of the international principles relating to transfer pricing in its domestic legislation as encapsulated in section 31 of the Income Tax Act No. 58 of 1962. Transfer pricing is currently one of the more important short term international tax considerations, specifically in the South African context where recent amendments, particularly with regard to thin capitalisation, have created a degree of commercial uncertainty for multinational enterprises. With regard to the South African context, this paper seeks to illustrate the increased compliance burden placed on South African taxpayers as a result of the 2012 amendment to section 31 of the Income Tax Act. While the revised section is aimed at reducing transfer pricing manipulation, the impact thereof on taxpayers is significant from both an administrative as well as financial perspective. In addition to evaluating the international principles and South Africa’s use thereof, this paper will also look at the extent to which developing countries are disadvantaged by the current transfer pricing framework. It is posited that the lack of access to resources, skills and expertises makes developing countries particularly vulnerable to base erosion and profit shifting by multinational enterprises.en_ZA
dc.identifier.apacitationDean, K. A. (2014). <i>Transfer pricing : an evaluation of section 31 of the Income Tax Act</i>. (Thesis). University of Cape Town ,Faculty of Law ,Department of Commercial Law. Retrieved from http://hdl.handle.net/11427/9172en_ZA
dc.identifier.chicagocitationDean, Kirsty Ann. <i>"Transfer pricing : an evaluation of section 31 of the Income Tax Act."</i> Thesis., University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2014. http://hdl.handle.net/11427/9172en_ZA
dc.identifier.citationDean, K. 2014. Transfer pricing : an evaluation of section 31 of the Income Tax Act. University of Cape Town.en_ZA
dc.identifier.ris TY - Thesis / Dissertation AU - Dean, Kirsty Ann AB - The focus of this paper is on South Africa’s implementation and application of the international principles relating to transfer pricing in its domestic legislation as encapsulated in section 31 of the Income Tax Act No. 58 of 1962. Transfer pricing is currently one of the more important short term international tax considerations, specifically in the South African context where recent amendments, particularly with regard to thin capitalisation, have created a degree of commercial uncertainty for multinational enterprises. With regard to the South African context, this paper seeks to illustrate the increased compliance burden placed on South African taxpayers as a result of the 2012 amendment to section 31 of the Income Tax Act. While the revised section is aimed at reducing transfer pricing manipulation, the impact thereof on taxpayers is significant from both an administrative as well as financial perspective. In addition to evaluating the international principles and South Africa’s use thereof, this paper will also look at the extent to which developing countries are disadvantaged by the current transfer pricing framework. It is posited that the lack of access to resources, skills and expertises makes developing countries particularly vulnerable to base erosion and profit shifting by multinational enterprises. DA - 2014 DB - OpenUCT DP - University of Cape Town LK - https://open.uct.ac.za PB - University of Cape Town PY - 2014 T1 - Transfer pricing : an evaluation of section 31 of the Income Tax Act TI - Transfer pricing : an evaluation of section 31 of the Income Tax Act UR - http://hdl.handle.net/11427/9172 ER - en_ZA
dc.identifier.urihttp://hdl.handle.net/11427/9172
dc.identifier.vancouvercitationDean KA. Transfer pricing : an evaluation of section 31 of the Income Tax Act. [Thesis]. University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2014 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/9172en_ZA
dc.language.isoengen_ZA
dc.publisher.departmentDepartment of Commercial Lawen_ZA
dc.publisher.facultyFaculty of Lawen_ZA
dc.publisher.institutionUniversity of Cape Town
dc.titleTransfer pricing : an evaluation of section 31 of the Income Tax Acten_ZA
dc.typeMaster Thesis
dc.type.qualificationlevelMasters
dc.type.qualificationnameLLMen_ZA
uct.type.filetypeText
uct.type.filetypeImage
uct.type.publicationResearchen_ZA
uct.type.resourceThesisen_ZA
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