I wrote an article on the IBOR transition from a South African perspective about a year ago. The article focused on what “IBOR transition” means and on how to get ready for it should you have active arrangements referencing IBOR. You can find the article here.
From earlier this year some IBOR rates are no longer published. The big example is USD LIBOR, which many have referenced to provide for an interest rate in their agreements. Let’s assume we still have agreements in place as of right now that reference USD LIBOR but as this is no longer published, how do I determine my interest rate. This also assumes the agreement does not have another rate to use in case USD LIBOR is no longer available. The below are some points to consider from a transfer pricing perspective. There are potential other tax consequences that may also arise from this but I have tried to stay clear of those, as it can be a lot to digest in one blog post.
Effective 1 July 2017, Malawi introduced two transfer pricing
(TP) related regulations. Firstly, the Taxation (Transfer Pricing
Documentation) Regulation which deals with transfer pricing documentation
requirements and secondly the Taxation (Transfer Pricing) Regulation which
covers general aspects of TP such as approved methods, key terms, guidance on
intangible property, general application and how to test related party
I am excited to let you know that we are back and that we have additional writers contributing now on a more permanent basis. Introductions will be made with the new blog posts, but for now, stay tuned. As always, if you have any suggestions please comment or send a message.
Also, I look forward to seeing you tomorrow at our TP Seminar.
The last few years have seen significant developments in the world of Transfer Pricing, including the Base Erosion and Profit Shifting project, the practical measures revenue authorities around the world have taken to implement the recommendations and increased levels of audit activity and Transfer Pricing court cases globally.
Closer to home, Transfer Pricing is top of mind for our Minster of Finance, the Commissioner of SARS and our politicians, and it should be high on the list of your priorities for 2018 too!
In this complimentary and interactive seminar to be held on Thursday the 15th of March, Grant Thornton’s Transfer Pricing team and external speakers will:
take attendees through the latest South African Transfer Pricing compliance requirements
differentiate between what taxpayers must do and should do from a documentation perspective
highlight what disclosures are required in the annual tax return discuss the practical considerations of implementing Transfer Pricing in a business
provide insight into what strategies should be employed for Transfer Pricing disputes and litigation
suggest how they can assist taxpayers in managing their Transfer Pricing compliance
If you are interested in joining me for the above, please register here. The seminar is free of charge and I hope you will come to enjoy a cup of coffee while chatting about TP.
What a busy week it has been with the third meeting on the Inclusive Framework on BEPS, including the release of some new draft reports. Furthermore, the final version of the toolkit addressing the lack of comparables was released. Lastly, FERMA provided draft guidance to the OECD on captive (re)insurance. Not that there wasnt enough reading material already.
Before going into more detail, I wanted to touch base on the picture. The search term “BEPS” is used now more often in Google searches than “transfer pricing.” It just shows how everything has shifted from a transfer pricing only world to a BEPS and value creation world. Another interesting, yet maybe not as academic observation, is that people stop searching for transfer pricing over Christmas, which doesn’t seem to be true for BEPS. But let’s get back to the transfer pricing roundup (or maybe I should call it a BEPS roundup?). Continue reading “Weekly transfer pricing roundup – 26 June 2017”