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# SARS just opened its new tax-certainty deal to far more companies
- URL: https://www.businessbagel.com/sars-just-opened-its-new-tax-certainty-deal-to-far-more-companies/
- Published: 2026-08-12T03:15:00.000Z
- Updated: 2026-08-12T03:14:59.000Z
- Description: After industry called the original bar unrealistic, the taxman cut the entry threshold for its new upfront pricing deals from R50bn to R10bn.
- Author: Christian Maidman
- Tags: Policy, Business Bagel News

When SARS first sketched out its new deal for big multinationals, almost no one qualified — and the accountants said so. Now the taxman has listened. In a notice gazetted on Friday, the South African Revenue Service set the entry bar for its new advance pricing agreements at R10-billion in annual revenue, a steep cut from the R50-billion it first proposed.

An advance pricing agreement, or APA, is an upfront deal between a company and one or more tax authorities that locks in how cross-border transactions between related parts of the same group will be taxed. The point is certainty: agree the method in advance and you avoid years of costly disputes and the risk of being taxed twice. It is the kind of thing large, globally spread companies value — but only if they can actually get in the door.

## Why R50bn didn't work

That was the whole problem with the first draft. The South African Institute of Chartered Accountants told SARS that a R50-billion revenue bar per taxpayer was "excessively high" and "disconnected from the commercial realities" of the local market. It pointed out that even the country-by-country reporting threshold sits at R10-billion for a whole group, and only about 60 multinational groups in the country clear that. Forvis Mazars called the R50-billion bar "overly restrictive". Very few taxpayers would have qualified, leaving the programme inaccessible to most of the companies actually facing complex transfer-pricing questions.

## What it still costs

Getting a lower bar does not make this cheap. A qualifying transaction must still exceed R1-billion for distribution or manufacturing, or R300-million for intragroup services. And companies face a R100,000 pre-application consultation fee plus a R1-million fee to process the application itself.

The regime has been a long time coming — first floated in a 2020 discussion paper, with the enabling law having taken effect on 22 December 2023\. SARS says it is starting with a pilot precisely because these cases are specialised and resource-intensive. It now begins as a bilateral-only pilot during 2026, accepting deals involving one other country's tax authority at a time before the programme's scope is widened. The real test is who lines up first.