SARS Notices and Guide for Bilateral APA Pilot Program

The South African Revenue Service (SARS) has announced the recent promulgation of a series of income tax notices concerning bilateral advance pricing agreements (APAs) under a tax treaty (double taxation agreement - DTA). As previously reported, the system for South Africa's APA program was introduced by the Tax Administration Laws Amendment Act 2023. SARS is implementing the system with a limited pilot phase, accepting only bilateral APA applications to start, which are referred to as DTA a…