“advance pricing agreement” means-

(a)     a DTA advance pricing agreement; and

(b)     a unilateral advance pricing agreement;

“advance pricing agreement application” means an application by a person to the Commissioner under section 76F(1) to enter into an advance pricing agreement;

“affected transaction” means an affected transaction, as defined in section 31, excluding paragraph (b) of the definition;

“affected party” means a person that is a party to an affected transaction;

“agreement for the avoidance of double taxation” means an agreement under section 108 that contains Articles that are the same as, or similar to, Article 9(2) and Article 25(3), as amended from time to time, of the Model Tax Convention on Income and on Capital of the Organisation for Economic Co-operation and Development;

“applicant” means a person who submits an advance pricing agreement application to SARS;

“arm’s length allocation” means an allocation of the profit in an affected transaction that would have been the allocation of the profit if the affected parties had been independent persons dealing at arm’s length with each other;

“arm’s length transfer price” means a transfer price in an affected transaction that would have been the transfer price if the affected parties had been independent persons dealing at arm’s length with each other;

“competent authority” is an official in a country who is authorised by the government of the country to administer an agreement for the avoidance of double taxation that the Republic is a party to, and includes a person duly delegated by that official to perform the role;