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How would a downgrade affect transfer pricing? In simple terms this would mean that South Africa will have to pay a higher interest rate for its debt as South Africa is seen as a riskier investment by lenders.
This will have knock on effects on the economy and in short, it may play out as follows. Transfer pricing is very fact dependent but I will try explore this topic on a generic basis.
The first thing that comes to mind is that companies are less likely to make profits in an economy that is in a recession. Companies that make losses are generally seen by tax authorities of greater risk as they are perceived to shift profits. So the questions here is whether the losses are due to commercial activities or due to transfer pricing arrangements.
But will this solve the issue? This causes similar issues as the above, and with a downgrade this is only likely to get worse. Companies which previously had acceptable amounts of debt now may be thinly capitalised and therefore may not be allowed to deduct the full interest expense as a tax deduction.
One must also keep in mind that South Africa has exchange controls in place to monitor cross border payments. Another point to mention is where South African companies are remunerated on a cost plus basis, be it on a gross cost or return on total costs see differentiation herethese companies are now becoming less competitive as doing business in South Africa overall is becoming more expensive.objective motivation problem.
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