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Transfer Pricing and Cross Border Tax Planning

South African Revenue Service scrutiny of related party transactions has intensified across mining, manufacturing and services groups with regional subsidiaries. This course works through arm's length principles, benchmarking studies, intercompany agreements and documentation standards, using African group structures to show where transfer pricing positions typically fail on audit and how finance teams can defend them credibly.

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What you will be able to do

  • Apply the arm's length principle to intercompany transactions across African subsidiaries.
  • Select and defend appropriate transfer pricing methods for goods, services and financing.
  • Prepare local file and master file documentation that meets SARS expectations.
  • Structure intercompany agreements that align with actual conduct and value creation.
  • Anticipate common transfer pricing adjustments raised during SARS audits.
  • Coordinate transfer pricing positions with regional tax authorities to reduce double taxation risk.

Course outline

  1. 01Arm's length principle and comparability
  2. 02Transfer pricing methods explained
  3. 03Benchmarking and functional analysis
  4. 04Local file and master file documentation
  5. 05Intercompany agreements and conduct
  6. 06Financing and guarantee arrangements
  7. 07SARS audit triggers and defence
  8. 08Dispute resolution across jurisdictions

Who should attend

Group tax managers, finance directors, transfer pricing specialists and financial controllers responsible for related party transactions across African operations.

Dates, venues and fees

DatesVenueDaysFeeCalendarRegister
28 to 30 Sep 2026Dar es Salaam3US$1,500Closed
29 Sep to 1 Oct 2026Kigali3US$1,500Register
30 Sep to 2 Oct 2026Kampala3US$1,500Register
5 to 7 Oct 2026Accra3US$1,500Register
6 to 8 Oct 2026Lagos3US$1,500Register
7 to 9 Oct 2026Cairo3US$1,500Register
12 to 14 Oct 2026Mauritius3US$1,500Register
13 to 15 Oct 2026Dubai3US$1,500Register
14 to 16 Oct 2026Online3US$900Register
10 to 12 Nov 2026Johannesburg3R13,000Register
11 to 13 Nov 2026Cape Town3R13,000Register
16 to 18 Nov 2026Durban3R13,000Register
17 to 19 Nov 2026Pretoria3R13,000Register
18 to 20 Nov 2026Windhoek3US$1,500Register
23 to 25 Nov 2026Gaborone3US$1,500Register
24 to 26 Nov 2026Maseru3US$1,500Register
25 to 27 Nov 2026Mbabane3US$1,500Register
30 Nov to 2 Dec 2026Lusaka3US$1,500Register
1 to 3 Dec 2026Harare3US$1,500Register
2 to 4 Dec 2026Lilongwe3US$1,500Register
7 to 9 Dec 2026Blantyre3US$1,500Register
8 to 10 Dec 2026Mozambique3US$1,500Register
9 to 11 Dec 2026Nairobi3US$1,500Register

Fees are per delegate. South African venues are priced in rand; other locations and online in US dollars. Fees exclude 15% VAT where applicable. Group bookings of three or more delegates from the same organisation qualify for a reduced rate; contact us for a quotation.

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