The South African Revenue Service (SARS) has published for consultation a high-level model and draft legislative framework for an advance pricing agreement (APA) unit and associated processes at SARS and the introduction of an APA program. This follows a discussion paper consulted on in 2020 for the introduction of an APA program to improve dispute resolution and tax certainty with respect to transfer pricing. SARS currently has an advance tax ruling system, although this does not cater for …