To object or take SARS on review – that is the question
A recent transfer pricing case raised a number of interesting issues about procedure in the event that a taxpayer disputes SARS’s findings following an audit South Africa has seen its third "transfer pricing" case which, once again, does not actually deal with the merits of the transfer pricing analysis. Following on from Crookes Bros and the ABC case, United Manganese of Kalahari (Pty) Ltd v The Commissioner for the South African Revenue Service considers the merits of procedure as opposed to the merits of the transfer pricing analysis under audit.
Source: polity.org.za