- Title
- Transfer pricing: an analysis of legislation in the southern African Customs Union
- Creator
- Patel, Nabil Ahmed
- ThesisAdvisor
- Stack, E
- ThesisAdvisor
- Mabaso, Sazi
- Subject
- Transfer pricing
- Date
- 2022-04-06
- Type
- Master's theses
- Type
- text
- Identifier
- http://hdl.handle.net/10962/241482
- Identifier
- vital:50943
- Description
- Transfer pricing is defined as the setting of the price for goods sold and services rendered between related entities. For example, if a subsidiary company sells goods or renders services to its holding company or a sister company, the price charged is referred to as the transfer price. Transfer pricing can be used to manipulate profits and facilitate tax evasion. Therefore, it is important that countries enact transfer pricing legislation to prevent this. The United Nations (UN) and Organisation for Economic Co-operation and Development (OECD) guideline documents form the basis for most global legislation and conventions dealing with transfer pricing. The over-arching goal of this research was to investigate whether transfer pricing legislation in the Southern African Customs Union (SACU) aligns between SACU countries and with the OECD Guidelines and the UN Manual. The research applied a legal interpretive doctrinal research methodology and a qualitative research method. The data comprised primary legislation in the SACU countries, transfer pricing guidelines issued by revenue authorities in the SACU, OECD Guidelines, the UN Manual and journal articles. It was found in this study that certain aspects of transfer pricing legislation in the SACU are not fully aligned to each other and to the OECD Guidelines and the UN Manual. This study proposed recommendations to improve transfer pricing legislation in the SACU. These improvements include the introduction of transfer pricing legislation in Eswatini and Lesotho, and updating transfer pricing legislation in Namibia and South Africa in terms of the latest versions of the OECD Guidelines and the UN Manual.
- Description
- Thesis (MCom) -- Faculty of Commerce, Accounting, 2022
- Format
- computer, online resource, application/pdf, 1 online resource (101 pages), pdf
- Publisher
- Rhodes University, Faculty of Commerce, Accounting
- Language
- English
- Rights
- Patel, Nabil Ahmed
- Rights
- Use of this resource is governed by the terms and conditions of the Creative Commons "Attribution-NonCommercial-ShareAlike" License (http://creativecommons.org/licenses/by-nc-sa/2.0/)
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| Thumbnail | File | Description | Size | Format | |||
|---|---|---|---|---|---|---|---|
| View Details Download | SOURCE1 | Patel - thesis with final corrections.pdf | 609 KB | Adobe Acrobat PDF | View Details Download |