South African Revenue Service (SARS)
Position Reports to: Business Area Lead Transfer Pricing
Division: Service & Delivery Large&Inter
Location: Woodmead North Office Park
Advert Closing Date: 1 September 2025
About the Position
A significant amount of cross-border trade and transactions are facilitated through connected parties or entities. Transfer pricing rules are intended to ensure that these transactions are conducted at arm’s length and that the terms at which these transactions take place are comparable to those that would apply to unrelated parties. An APA Programme ensures that there is upfront agreement with the affected taxpayer on the appropriate transfer price. An APA programme directly aligns SARS strategic objectives. It provides clarity and certainty for taxpayers and traders with respect to their tax obligations. An APA simplifies the understanding and application of complex transfer pricing laws to specific international transactions. Internationally, APAs are recognised as a critical tool to move from a dispute resolution system to a dispute prevention system. The OECD’s BEPS Action 14: Improving tax dispute resolution mechanisms, recognises APAs as a mechanism of reducing tax disputes, thus reducing the pressure on already constrained transfer pricing audit resources. This ensures that transfer pricing audit resources can take a completely risk-based approach, focusing on detecting taxpayers who are unwilling to comply, and making it hard and costly for non-compliance.
Job Purpose
The Advanced Pricing Agreement (APA) auditor needs to be able to plan and conduct a transfer pricing assessment to assess the technical appropriateness of an APA in relation to each APA application in compliance with all legislative requirements.
Education and Experience
Minimum Qualification & Experience Required
Relevant Bachelor’s Degree / Advanced Diploma (NQF 7) and 5-7 years’ experience in International and/or Transfer Pricing environment of which 2-3 years at Corporate Income Tax technical specialist level.