South Africa’s First Transfer Pricing Case


I’d like to refer to the article: “South Africa’s first Transfer Pricing case, and it’s a win for the taxpayer!

Transfer pricing is critical, especially when ensuring compliance with local tax regulations. The case of ABD Limited vs. The Commissioner for the South African Revenue Service (SARS) sheds light on the complexities and challenges surrounding transfer pricing practices in South Africa. This matter highlights the potential pitfalls for multinational companies and demonstrates the vital role of expert legal teams, such as TRM, in navigating these challenges successfully.

The Importance of the Case

Transfer pricing, the practice of setting prices for transactions between companies within the same corporate group, is crucial for tax purposes. It ensures that transactions with foreign subsidiaries are priced as if they were conducted between unrelated parties, maintaining fairness and preventing tax evasion. The ABD Limited case raises unique questions about transfer pricing, especially concerning the royalties for intellectual property rights and how they should be calculated to comply with South Africa’s tax laws.

TRM’s Role

This significant case underscores the expertise and effectiveness of’s team. Specializing in transfer pricing disputes, we provided unparalleled guidance through this complex tax litigation process, demonstrating our deep understanding of South African tax laws and international transfer pricing principles. The strategic approach and meticulous preparation were instrumental in challenging SARS’s increased assessment based on the arm’s length principle—a cornerstone of transfer pricing regulations.


Dr. Daniel N. Erasmus’s Upcoming Contributions

Dr. Daniel N. Erasmus further explores these complexities in his upcoming book: “Conducting a TP Trial.” His work promises to be an essential resource for legal practitioners and multinational corporations, offering deep insights into the strategic considerations and legal frameworks surrounding transfer pricing trials.

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