What happened?
South Africa’s Revenue Service published Issue 4 of its Guide on Mutual Agreement Procedures on 23 October 2026. The guide addresses the treaty process through which competent authorities seek to resolve taxation inconsistent with an applicable double taxation agreement.
Key details
The relevant treaty controls eligibility and the submission deadline. A three-year period from first notification applies under many treaties, but taxpayers must check the particular agreement. The guide is general guidance, rather than a binding ruling or a substitute for legislation and treaty text.
Who is affected?
Businesses facing cross-border transfer-pricing adjustments, disputed residence or treaty-inconsistent withholding may need to consider MAP. The availability of the procedure and the outcome depend on the facts and treaty provisions.
Business impact
Tax & Markets analysis: teams should maintain a separate timetable for MAP and domestic objections or appeals, preserve assessment and transaction evidence, and quantify the disputed double tax. Do not assume a MAP request preserves every domestic right or automatically secures repayment.
Sources
Primary and secondary sources are distinguished below. See our methodology for verification and correction standards.
Publication status: Published following editorial source review.