Deepening Democracy through Access to Information
Home / Press Office / Other Briefs RSS ← Back

Email this article

separate emails by commas, maximum limit of 4 addresses

Verification Image. Please refresh the page if you cannot see this image.

Sponsored by


Article Enquiry

A new era in transfer pricing risk assessment

Verification Image. Please refresh the page if you cannot see this image.

Embed Video

A new era in transfer pricing risk assessment

10th November 2017


Font size: -+

A toolkit for Transfer Pricing Risk Assessment in the African Mining Industry was launched in September this year by the African Tax Administration Forum (ATAF) at its International Conference on Tax in Africa (ICTA). This toolkit signals the next wave of intensified effort by tax administrations in Africa in the area of transfer pricing. The toolkit is the result of a joint effort by ATAF and the German Federal Ministry for Economic Cooperation and Development.
Risk assessment by tax administrations is intended to ensure a more targeted approach to audit case selection. Experienced tax administrations have been applying sophisticated risk assessment procedures for years. It is well known that the South African Revenue Services has an entire unit dedicated to risk assessment across various tax types. In the effort to improve tax collections, risk assessment remains a critical component of selecting cases for audit that are likely to have the highest tax yield.

This step by the ATAF demonstrates the continuing political will by tax administrations in Africa to tackle Base Erosion and Profit Shifting and Illicit Financial Flows, where transfer pricing is perceived as being a key culprit.

The Toolkit is available on the ATAF website and contains a step-by-step guide to assessing risk, culminating in a risk rating. Having developed such a toolkit, it is also recognised that risk assessment does not exclude the need for specialist judgement and discretion.

This effort by the ATAF is one of several to promote effective tax administrations in Africa. Other measures to aid in the enforcement of transfer pricing include the development of:

  • robust legislation to effect access to information;
  • specific tax return filing to aid in data analytics;
  • e-filing that can aid automated risk assessment;
  • training and after-support to build audit capacity;
  • governance processes to ensure due process; and
  • agreements with database service providers.

As a major emerging market, Africa has much to offer and the above efforts are both welcome and encouraging.

Written by Nishana Gosai, Senior Executive: Transfer Pricing, Baker McKenzie Johannesburg



To subscribe email or click here
To advertise email or click here

Comment Guidelines

About is a product of Creamer Media.

Other Creamer Media Products include:
Engineering News
Mining Weekly
Research Channel Africa

Read more


We offer a variety of subscriptions to our Magazine, Website, PDF Reports and our photo library.

Subscriptions are available via the Creamer Media Store.

View store


Advertising on is an effective way to build and consolidate a company's profile among clients and prospective clients. Email

View options
Free daily email newsletter Register Now