The South Africa Revenue Service (SARS) released a public notice (the Notice) on October 28, setting out record-keeping requirements with respect to "potentially affected transactions." The Notice contains a schedule (the Schedule) that indicates to which taxpayers the Notice applies, and which records, books of account or documents are to be kept by such taxpayers. The Notice applies to years of assessment commencing on or after October 1, 2016. While there is some overlap between the information mentioned in the Schedule and information that is typically found in a transfer pricing documentation report, it is important to note that the Notice does not require taxpayers to include all information in a separate report. It is expected that specific transfer pricing documentation requirements, in line with the final recommendations in the final report on Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting) of the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project will be released at a later stage.

A Tax Alert prepared by Ernst & Young South Africa, and attached below, provides additional details.

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Full text of Tax Alert 2016-1914