Tax, VAT, customs and trade alerts

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  • Publication
  • September 29, 2026

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.

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In this alert: 

Transfer Pricing Adjustments in customs now have a defined SARS process

SARS has enacted new Rules ("the new Rules")  to the Customs and Excise Act, No 91 of 1964 (“the Act”). The new Rules to Sections 40 and 41A to the Act took effect on 14 September 2026. These Rules relate to Transfer Pricing ("TP") Adjustments between related companies of multinational enterprises that will have an effect on the customs value of goods imported.

The change in rules impacts importers in multinational groups raising or receiving interim or year‑end TP Adjustments and will have an effect on the customs value of goods imported.

The Act now sets out the required notification, submission, payment and refund steps, while the new Rules provide detailed requirements regarding the steps to be followed and the supporting documentation expected by SARS.

The below Alert provides more details regarding the matter.

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Kyle Mandy

Kyle Mandy

Africa Tax Policy Leader, PwC South Africa

Tel: +27 (0) 11 797 4977

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