South Africa releases model legislation to introduce Advance Pricing Agreement Programme

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  • By Chetan Kulasri
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  • Last Updated on 17 February, 2026

South African Advance Pricing Agreement Programme; APA; Transfer Pricing

News, dated 27-12-2021

In keeping with international developments, the South African Revenue Service (SARS) published a high-level model and drafted legislation for an advance pricing agreement (APA) unit and associated processes. The APA Program aims to provide clarity and certainty to the taxpayers of their obligations. The necessity of the APA unit is foundational in advancing SARS strategic agenda and restoring the organisation to world-class status.

SARS will accept feedbacks on model APA at acollins@sars.gov.za until January 31, 2022, and it is believed that the feedbacks will enable further streamlining of the model. The release of the model and draft will facilitate the comprehensive engagement of all the affected parties and lay a groundwork for the APA Programme.

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