On 28 July 2016, The South African Revenue Service (SARS) issued a final draft notice for public comment on additional record-keeping requirements for transfer pricing. The main differences between the initial draft ({News-2015-12-18/P/3- previous coverage}) and the final draft is a change in the persons subject to the requirements and the introduction of a transaction-specific threshold.
Under the initial draft, persons subject to the requirements were those that have entered into potentia…