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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.

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SARS releases draft Public Notices on Advance Pricing Agreements

On 30 April 2026, SARS released six draft Public Notices setting out details of the proposed Advanced Pricing Agreement (‘APA’) programme. APAs are a regime whereby taxpayers can get upfront approval for their transfer pricing policy from SARS (and where there is a bilateral APA, the corresponding Revenue Authority) to achieve tax certainty. Amongst other things, the proposals included commentary on which taxpayers can qualify for the APA programme, which transactions are excluded, and the proposed fee structure. Public comments on the draft Public Notices must be submitted by the close of business on 29 May 2026. This represents a significant milestone in the operationalisation of the APA regime.

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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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