Andre Klynsmith

Supply Chain Management

Thirty Days, Then Fourteen: SARS Puts a Clock on Transfer-Pricing Customs Adjustments

New customs rules took effect on 14 September 2026 that change how multinational importers must handle a transfer-pricing adjustment. Published in Government Gazette 55355 on 11 September, the amendments to the Customs and Excise Act rules prescribe exactly how an importer must correct bills of entry when a transfer-pricing adjustment alters the declared customs value of imported goods.

SUPPLY CHAIN MANAGEMENT

19 September 2026 • 5 min read

The customs file no longer closes when the container is released. For importers buying from related parties, a year-end accounting adjustment now reopens every affected entry — on a 30-day clock, followed by a 14-day payment clock.

The process, step by step

An affected importer must first notify the South African Revenue Service of the adjustment and submit the relevant amended invoice or debit or credit note. It must then obtain the latest data relating to the affected bills of entry from SARS' Trade Statistics department.

Within 30 calendar days of submitting the notification, the importer must provide SARS with a completed Customs Value Adjustment Calculation — the CVAC spreadsheet — plus supporting documentation. The CVAC must show how the adjustment affects the customs value, the duty and the VAT payable on each affected bill of entry, line by line.

A finance department's document list

The required documents include the applicable transfer-pricing policy and calculation as well as signed annual financial statements. Depending on the circumstances, purchase and sale agreements, distribution agreements, segmented financial data and royalty or licence agreements may also be required.

That is not a logistics file. Signed financial statements and segmented financial data sit with the finance function, often in a parent company in another jurisdiction, yet the 30-day clock runs against the customs process. Where an adjustment produces a refund rather than a liability, the importer must submit a voucher of correction for each affected bill of entry. Bills of entry for warehousing may not be included in the CVAC at all and must be amended through a separate process prescribed under the Act.

Valuation is where the enforcement pressure sits

Customs and trade specialist Clifford Evans told Freight News the more detailed procedure formed part of a broader focus on customs valuation and enforcement. "There are more and more cases of customs insisting that duty be paid on charges that are clearly non-dutiable," he said, adding that "valuation is a high risk for SARS, along with tariff classification and countries of origin". Evans noted that none of his clients currently used transfer pricing and that his comments related to the broader direction of customs enforcement rather than the operation of the new rules.

One line in the amendments deserves particular attention: SARS' acceptance of a CVAC does not protect an importer from subsequent audit findings, fines or penalties under the Act. Acceptance is not closure. For any importer running interim or year-end transfer-pricing adjustments, the practical question is now whether customs values declared on previous entries must also be amended — and that question has to be asked before the adjustment is booked, not after.

About the Author
	Andre Klynsmith Entrepreneur & Technology Enthusiast Andre's expertise spans technology, blockchain, transport, and logistics — with a passion for innovation and driving positive change across industries. info@laaimylorrie.com | laaimylorrie.com