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We provide a wealth of publications by PwC South Africa providing informed commentary on current developments in the tax arena, both locally and internationally.
Through analysis and comment on new law and judicial decisions of interest, they assist business executives to identify developments and trends in tax law and revenue practice that might impact their business.
In this alert:
Special Economic Zones: Introduction of domestic transfer pricing rules (proposed section 31B)
On 30 July 2026, National Treasury and the South African Revenue Service (“SARS”) published the 2026 Draft Taxation Laws Amendment Bill (“TLAB”) for public comment. The draft TLAB proposes the introduction of a new section 31B to the Income Tax Act, which will apply the arm’s length principle to domestic related-party transactions involving Special Economic Zone (“SEZ”) companies qualifying for the reduced 15% corporate income tax rate.
This is a significant shift from the current 20% threshold test in section 12R(4)(c) to a full transfer pricing analysis requirement. Comments on the draft Bill is due by 28 August 2026.
The below Alert provides more details regarding the matter.
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