Strategizing International Tax Best Practices – by Keith Brockman

SARS Draft Interpretation Note, issued March 22, 2013, describes in Section 7 “Risk Assessment and Selection of Cases for Audit,” concepts for determination of thin capitalization thresholds and an arms-length rate of interest on inbound loans.  The Note is attached for reference.  From a Best Practices approach, I have the following queries:

  • How are Treasury & Tax functions aligned to maximize opportunities for this type of development?
  • How are you timely notified of such developments (i.e. local Business, external advisors, Tax Notes Int’l., etc)
  • Does your company have a stated process re: providing public comment for such guidance?
  •  From a RACI Model perspective, are roles aligned to address this Note?
  • Who determines if proactive debt/equity planning scenarios are reviewed, and relevant timelines?
  • How are the proposed transfer pricing analyses integrated into the transfer pricing documentation framework?

I welcome your input.


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