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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.

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

DatesVenueDaysFeeCalendar
24 to 26 Aug 2026Online3US$900
31 Aug to 2 Sep 2026Mozambique3US$1,500
7 to 9 Sep 2026Cairo3US$1,500
14 to 16 Sep 2026Accra3US$1,500
21 to 23 Sep 2026Lusaka3US$1,500
28 to 30 Sep 2026Kigali3US$1,500
5 to 7 Oct 2026Nairobi3US$1,500
12 to 14 Oct 2026Durban3R13,000
19 to 21 Oct 2026Johannesburg3R13,000
2 to 4 Nov 2026Mauritius3US$1,500
9 to 11 Nov 2026Dubai3US$1,500
16 to 18 Nov 2026Lagos3US$1,500
23 to 25 Nov 2026Harare3US$1,500
30 Nov to 2 Dec 2026Kampala3US$1,500
7 to 9 Dec 2026Dar es Salaam3US$1,500
14 to 16 Dec 2026Pretoria3R13,000
21 to 23 Dec 2026Cape Town3R13,000

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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