Paper by: SARS
This is a general guidance on the mutual agreement procedure (MAP) that allows competent authorities from the governments of contracting jurisdictions to interact with the intent to resolve international tax disputes.
It does not delve into the precise technical and legal detail that is often associated with tax, and should, therefore, not be used as a legal reference.
This guide is not an “official publication” as defined in section 1(1) of the Tax Administration Act 28 of 2011 and accordingly does not create a practice generally prevailing under section 5 of that Act. It is also not a binding general ruling under section 89 of Chapter 7 of the Tax Administration Act. Should an advance tax ruling be required, visit the SARS website for details of the application procedure.