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Transfer pricing : an evaluation of section 31 of the Income Tax Act
Includes bibliographical references.
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| Main Author: | |
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| Other Authors: | |
| Format: | Thesis |
| Language: | English |
| Published: |
Department of Commercial Law
2014
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| _version_ | 1867613245752213504 |
|---|---|
| access_status_str | Open Access |
| author | Dean, Kirsty Ann |
| author2 | Gutuza, Tracy |
| author_browse | Dean, Kirsty Ann Gutuza, Tracy |
| author_facet | Gutuza, Tracy Dean, Kirsty Ann |
| author_sort | Dean, Kirsty Ann |
| collection | Thesis |
| description | Includes bibliographical references. |
| format | Thesis |
| id | oai:open.uct.ac.za:11427/9172 |
| institution | University of Cape Town (South Africa) |
| language | eng |
| last_indexed | 2026-06-10T12:33:05.164Z |
| license_str | Not specified — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository |
| publishDate | 2014 |
| publishDateRange | 2014 |
| publishDateSort | 2014 |
| publisher | Department of Commercial Law |
| publisherStr | Department of Commercial Law |
| record_format | dspace |
| source_str | UCTD — University of Cape Town Open Access Repository |
| spelling | oai:open.uct.ac.za:11427/9172 Transfer pricing : an evaluation of section 31 of the Income Tax Act Dean, Kirsty Ann Gutuza, Tracy Includes bibliographical references. 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. 2014-11-05T03:54:05Z 2014-11-05T03:54:05Z 2014 Master Thesis Masters LLM http://hdl.handle.net/11427/9172 eng application/pdf Department of Commercial Law Faculty of Law University of Cape Town |
| spellingShingle | Dean, Kirsty Ann Transfer pricing : an evaluation of section 31 of the Income Tax Act |
| thesis_degree_str | Master's |
| title | Transfer pricing : an evaluation of section 31 of the Income Tax Act |
| title_full | Transfer pricing : an evaluation of section 31 of the Income Tax Act |
| title_fullStr | Transfer pricing : an evaluation of section 31 of the Income Tax Act |
| title_full_unstemmed | Transfer pricing : an evaluation of section 31 of the Income Tax Act |
| title_short | Transfer pricing : an evaluation of section 31 of the Income Tax Act |
| title_sort | transfer pricing an evaluation of section 31 of the income tax act |
| url | http://hdl.handle.net/11427/9172 |
| work_keys_str_mv | AT deankirstyann transferpricinganevaluationofsection31oftheincometaxact |