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Understanding and managing risks at the intersection of transfer pricing and customs valuation rules
Mini Dissertation (LLM)--University of Pretoria, 2016.
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| Format: | Thesis |
| Language: | English |
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University of Pretoria
2017
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| _version_ | 1867613569379467264 |
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| access_status_str | Open Access |
| author2 | Fritz, Carika |
| author_browse | Fritz, Carika |
| author_facet | Fritz, Carika |
| collection | Thesis |
| dc_rights_str_mv | © 2017 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. |
| description | Mini Dissertation (LLM)--University of Pretoria, 2016. |
| format | Thesis |
| id | oai:repository.up.ac.za:2263/60045 |
| institution | University of Pretoria (South Africa) |
| language | English |
| last_indexed | 2026-06-10T12:38:13.749Z |
| license_str | Other — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository |
| publishDate | 2017 |
| publishDateRange | 2017 |
| publishDateSort | 2017 |
| publisher | University of Pretoria |
| publisherStr | University of Pretoria |
| record_format | dspace |
| source_str | UPSpace — University of Pretoria Institutional Repository |
| spelling | oai:repository.up.ac.za:2263/60045 Understanding and managing risks at the intersection of transfer pricing and customs valuation rules Fritz, Carika kyle.fyfe@nortonrosefulbright.com Fyfe, Kyle Jason UCTD Transfer Pricing Customs Valuation Taxation (South Africa) Customs (South Africa) Law theses SDG-16 SDG-16: Peace, justice and strong institutions Mini Dissertation (LLM)--University of Pretoria, 2016. Transfer pricing and customs valuation rules, are both ultimately aimed at ensuring a transaction with an associated enterprise or related party is conducted at arm?s length. The literature on the intersection of these rules has identified, on the one hand, the potential for double taxation and, on the other hand, exploitation of the differences in these regimes by taxpayers. After identifying the obstacles to harmonisation of customs valuation and transfer pricing rules and the opportunities for applying these rules in a harmonised way (in order to manage the risks associate with these rules), this mini-dissertation critically analyses the South African income tax and customs legislation and evaluates it by way of a case study based on the author?s recent experience. This analysis and case study illustrates that in general transfer pricing documentation cannot be used to show that the transaction value of the imported goods is arm?s length and that the prospects for harmonisation of transfer pricing and customs valuation rules in South Africa are poor. The means of managing the transfer pricing and customs valuation risks identified in the existing literature and the case study are further analysed to identify whether they are feasible in South Africa. It is established that importers should incorporate information relevant to customs authorities in their transfer pricing documentation and use provisional declarations where future transfer pricing adjustments are expected. The importer should also evaluate its transfer prices continually in order to avoid year-end transfer pricing adjustments. Mercantile Law LLM Unrestricted 2017-04-26T11:51:39Z 2017-04-26T11:51:39Z 2017/04/06 2016 Mini Dissertation Fyfe, KJ 2016, Understanding and managing risks at the intersection of transfer pricing and customs valuation rules, LLM Mini Dissertation, University of Pretoria, Pretoria, viewed yymmdd <http://hdl.handle.net/2263/60045> A2017 http://hdl.handle.net/2263/60045 en © 2017 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. application/pdf University of Pretoria |
| spellingShingle | UCTD Transfer Pricing Customs Valuation Taxation (South Africa) Customs (South Africa) Law theses SDG-16 SDG-16: Peace, justice and strong institutions Understanding and managing risks at the intersection of transfer pricing and customs valuation rules |
| title | Understanding and managing risks at the intersection of transfer pricing and customs valuation rules |
| title_full | Understanding and managing risks at the intersection of transfer pricing and customs valuation rules |
| title_fullStr | Understanding and managing risks at the intersection of transfer pricing and customs valuation rules |
| title_full_unstemmed | Understanding and managing risks at the intersection of transfer pricing and customs valuation rules |
| title_short | Understanding and managing risks at the intersection of transfer pricing and customs valuation rules |
| title_sort | understanding and managing risks at the intersection of transfer pricing and customs valuation rules |
| topic | UCTD Transfer Pricing Customs Valuation Taxation (South Africa) Customs (South Africa) Law theses SDG-16 SDG-16: Peace, justice and strong institutions |
| url | http://hdl.handle.net/2263/60045 |