ABD Limited v Commissioner for the South African Revenue Service (14302)
ABD Limited v Commissioner for the South African Revenue Service (14302) [2024] ZATC 2; 87 SATC 64 (14 February 2024)
The Tax Court held that ABD’s 1% royalty was arm’s length, relying on a Cyprus internal CUP, and set aside SARS’s increased assessments.
- Transfer Pricing
- Arms Length Principle
- Royalty Payments
- Income Tax Act Section 31
- Tax Administration Act Section 129
- Comparable Uncontrolled Price Method