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Tax Administration Act, 2011 (Act No. 28 of 2011)


Regulations for purposes of Paragraph (b) of the Definition of "International Tax Standard" in Section 1 of the Tax Administration of the Tax Administration Act, 2011 (Act No. 28 of 2011), promulgated under Section 257 of the Act, Specifying the Country-By-Country Reporting Standard for Multinational Enterprises

Article 6 : Use and Confidentiality of Country-by-Country Report Information


1. SARS must only use the Country-by-Country Report for purposes of assessing high-level transfer pricing risks and other base erosion and profit shifting related risks in South Africa, including assessing the risk of non-compliance by members of the MNE Group with applicable transfer pricing rules, and where appropriate for economic and statistical analysis. Transfer pricing adjustments by SARS may not be based on the Country-by-Country Report.


2. SARS must preserve the confidentiality of the information contained in the Country-by-Country Report at least to the same extent that would apply if such information were provided to it under the provisions of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.