SAICA submission on the draft public notices in respect of the Advance Pricing Agreement programme

This submission is SAICA’s response to SARS’ draft public notices on the APA programme for transfer pricing, focusing on how the proposed rules would work in practice under sections 76C, 76D, 76I, 76J and 76P of the Income Tax Act. It argues that the draft notices are too restrictive and unclear in key areas—such as eligibility thresholds, fees, rejection criteria, taxpayer participation, confidentiality, and scope—and recommends changes to make the APA system more accessible, practical, and certain for taxpayers.