Section 31 of the income tax act 58, 1962 (“ita”) – A definition of transfer pricing and thin capitalisation

Section 31 of the ITA provides special anti-avoidance rules to regulate certain international transactions and this article intends to define and explain the two concepts referred to in this Section of the ITA being transfer pricing and thin capitalisation. The Katz Commission’s interim report found that general anti-avoidance provisions were not sufficient to counter practices where prices for the supply [...]