The South African Revenue Service (SARS) has reported a new inbound service disclosure requirement due in mid-April 2016. Penalties are applicable for late filing.
It is expected that SARS will use the information collated to assess the risk of tax exposures resulting from permanent establishments, transfer pricing, VAT, employees’ tax and potential exchange control violations.
EY’s Global Tax Alert is provided for reference.
Best Practice thoughts for local disclosures:
- How does HQ/Regional Tax identify local tax (primarily BEPS related) disclosures that require information possibly not known by the local entity?
- What type of governance/control process exists to ensure important filings are not missed?
- Are external advisor(s) being relied upon to inform a MNE of all such disclosures?
- Is a master calendar available for such filings?
- Who is responsible for identifying new disclosures?
- Is there a single point of tax contact for such filings?
- Are internet sites relied on partially/exclusively for updates?
This new disclosure brings Best Practice ideas into action, as such filings are easy to miss if not identified timely.