Transfer Pricing Masterclass - Johannesburg

Overview

The OECD/G20 Inclusive Framework recently published an update on the work to overhaul the international tax rules for the taxation of the digitalising economy. Should the Inclusive Framework reach consensus, the international tax system (in particular nexus to tax and profit allocation rules) will change dramatically.

The OECD/G20 Inclusive Framework has reiterated its commitment to achieving agreement within 2020 and has endorsed a “Unified Approach” as a basis for further negotiations towards an agreement. The paper released by the OECD provided updated guidelines on the calculations of Amounts A, B and C, and a summary of the specific aspects that still need to be clarified.

In February 2020, the OECD also issued updated Transfer Pricing Guidance on Financial Transactions, which follows on the non-consensus draft issued in July 2018. This updated guidance will now be incorporated in the OECD Transfer Pricing Guidelines.

Subsequent to the OECD report, the SA National Treasury also issued a public consultation document entitled “Reviewing the tax treatment of excessive debt financing, interest deductions and other financial payments”. Amongst other things the report seeks to introduce new interest limitation rules, potentially replacing the current section 23M of the Income Tax Act.

We invite you to join our next Transfer Pricing Masterclass, where we’ll discuss the proposed impact of these changes from a global and Africa perspective. The PwC panel will cover:

  • The Pillar 1 Unified Approach: Amounts A, B and C as a new approach to the allocation of global profits, taking the Africa viewpoint into account;
  • APAs and dispute prevention/resolution tools (Amount C);
  • Discontinuation of digital services taxes and other unilateral measures; and
  • The updated OECD Guidance on Financial Transactions, together with the South African National Treasury public consultation document.

Please find additional information below:

The Autum update sessions will focus on a broad range of topics including an overview of new standards and amendments, latest developments in IFRS and various hot topics.
The Autum update sessions will focus on a broad range of topics including an overview of new standards and amendments, latest developments in IFRS and various hot topics.
 
The Autum update sessions will focus on a broad range of topics including an overview of new standards and amendments, latest developments in IFRS and various hot topics.
 
The Autum update sessions will focus on a broad range of topics including an overview of new standards and amendments, latest developments in IFRS and various hot topics.
The Autum update sessions will focus on a broad range of topics including an overview of new standards and amendments, latest developments in IFRS and various hot topics.
The Autum update sessions will focus on a broad range of topics including an overview of new standards and amendments, latest developments in IFRS and various hot topics.
The Autum update sessions will focus on a broad range of topics including an overview of new standards and amendments, latest developments in IFRS and various hot topics.
The Autum update sessions will focus on a broad range of topics including an overview of new standards and amendments, latest developments in IFRS and various hot topics.

Event details

Date:  Tuesday, 31 March 2020
Time: 7.30am - 12pm

Venue:
PwC Waterfall,
4 Lisbon Lane,
Waterfall City,
Midrand

Cost: There is no cost for this masterclass

CBD: 3 hours verifiable CPD hours

RSVP: By Wednesday, 25 March 2020

 

Two men sitting in an office room

Our panelists will include:

  • Stefaan De Baets from PwC Belgium. Stefaan is an ex-OECD member where he collaborated on the BEPS project and was responsible for capacity building in foreign tax administrations, analysing and improving transfer pricing legislation, regulations and practices, developing guidance on transfer pricing and creating the Global Forum on Transfer Pricing for Tax Administrations. He is currently a director at PwC Belgium.
  • JP Borman – Transfer Pricing Partner, PwC South Africa
  • Titus Mukora – Transfer Pricing Partner, PwC Kenya
  • Seun Adu – Transfer Pricing Partner, PwC Nigeria

 

Contact us

Seshnee Naidoo

Manager, PwC South Africa

Tel: +27 (0)11 797 4145

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