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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:
APA Final SARS Notices - 7 August 2026
Taxpayers may submit requests, from 1 September 2026, to participate in South Africa’s highly anticipated Advance Pricing Agreement (“APA”) programme. On 7 August 2026, the South Africa Revenue Service (“SARS”) published the final Public Notices establishing the APA programme, accompanied by a comprehensive APA External Guide.
The pilot APA programme will be limited to bilateral APAs. Notable changes from the initial draft versions of the Public Notices include a significantly reduced turnover threshold of ZAR10Bn (reduced from R50Bn, and an expanded scope of qualifying intragroup services —to cover all services (rather than only imported services).
The below Alert provides more details regarding the matter.
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