SARS vs Taxpayer SC – CUP vs PSM
Overview
A summary of the Commissioner for the South Revenue Service v Taxpayer SC (Pty) Ltd (45840) [2025] ZATC 8 (15 April 2025) case in which the Court had to decide whether or not SARS should be granted permission to amend its Rule 31 statement as relates to the use of transfer pricing methodologies.
| Author | SAICA (Nomvula Masehla: Project Director) |
|---|---|
| Division | Tax |
| Keywords | Transfer Pricing Rule 31 statement Comparable Uncontrolled Price Profit Split Method |
| Categories | Tax |
| Date | 11 August 2025 |
| File |