“country of residence” is the country in which a person is considered to be a resident, after the application of an agreement for the avoidance of double taxation;

“DTA advance pricing agreement” means an agreement between an applicant and the competent authority of the Republic, in consultation with the competent authority of another country, which has an agreement for the avoidance of double taxation with the Republic, regarding the application of section 31 to an affected transaction in which the applicant is an affected party;

“transfer price” means the price at which persons trade a service, tangible property or intangible property with each other across international borders;

“transfer pricing method” means a transfer pricing method referred to in the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, as amended from time to time;

“unilateral advance pricing agreement” means an agreement between an applicant and the Commissioner regarding the application of section 31 to an affected transaction in which the applicant is an affected party.

[Section 76A inserted by section 10 of Act 18 of 2023]