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Showing 1 to 3 of 3 for “"Arm’s length price"”.
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Implementation of advanced pricing agreements by the South Africa Revenue Service: a critical review
… as the process by which related entities set prices at which they transfer goods or services between each other. Multinational entities (MNEs), by virtue of its global presence, are subject to different tax laws of different countries. Accordingly, MNEs can potentially set transfer prices that …
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Seeking arm’s length: An evaluation of formulary apportionment and predetermined margins as alternative or supplementary methods to establish proxy arm’s length transfer prices for multinational intercompany transactions in South Africa
… of the transfer pricing model is the use of the arm’s length price. In terms of the arm’s length principle, in order to test the reasonability of pricing within MNE’s, tax authorities should use a similar but unrelated open market transaction as the benchmark to determine if there were any profit …
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A critical analysis of SARS' implementation of Advance Pricing Agreements
… of these transactions. This has resulted in lengthy and costly dispute resolution processes that pose uncertainty for multinational enterprises when contemplating investment destinations. This study aims to critically analyse and discuss the impending implementation of advance pricing …