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S.Africa: Country by Country reporting

Country-by-Country Reporting and Transfer Pricing
SARS issued a public notice on 20 October 2017 which stipulates the requirements and timeframes for Country-by-Country Reporting (“CbCr”) and transfer pricing documentation (master file and local file). 

The requirements for CbCr which apply for financial years commencing on or after 1 January 2016 is a consolidated Multi-National Entities (“MNE”) group turnover of at least R10 billion in the fiscal year prior to the year in which the CbC report must be submitted. Where an entity is liable for CbCr, it is also required to submit its master and local file for the purposes of transfer pricing.

A crucial item that may easily be overlooked is where the CbCr of a MNE is not filed in South Africa, the SA resident entity of that MNE multinational enterprise need to inform SARS of the identity of the Ultimate Parent Entity filing the CbCr within 12 months after the last day of the Reporting Fiscal Year of the MNE. That means where the Ultimate Parent Entity of the group has a 31 December year end, the notification will be due by 31 December 2017.
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