South Africa requires multinational importers to follow a structured Customs Value Adjustment Calculation procedure when transfer-pricing adjustments affect declared customs values, effective September 14, 2026.
The South African Revenue Service (SARS), the country’s tax and customs agency, has set out new rules for how multinational importers must correct customs values after a transfer-pricing change, with effect from 14 September 20261.
The rules appear in Notice R.7900, published in Government Gazette No. 55355 on 11 September 20262. SARS Commissioner Ngobani Johnstone Makhubu signed the notice under the Customs and Excise Act, 19641.
In short, when a company buys goods from a related company abroad and later changes the price, the value on past customs declarations changes too. Under the new rules, the importer notifies SARS, sends a set spreadsheet within 30 days, and then pays extra duty or claims a refund.
What does transfer pricing mean for South African imports?
Transfer pricing is the price one part of a company group charges another part for goods. The notice defines a transfer-pricing adjustment as a change to the price at which a multinational imported goods into South Africa from a related party1. A related party is a linked company, as described in section 66(2)(a) of the customs law.
Such groups often fix the final price only after their accounts close. The supplier abroad then sends an amended invoice, or a debit or credit note. A debit note raises the price and a credit note lowers it.
Customs duty and VAT are charged on the customs value of the goods. So a later price change means the duty and VAT paid at the border were too high or too low. The new rules tell importers how to fix the bill of entry, the customs declaration made for each shipment2.
How must importers notify SARS about the price change?
The first step is a letter of notification. The importer, or its registered customs agent, must write it on company letterhead1. It must reach SARS within the time limit already set in section 41(4)(b)(ii)(bb) of the Act.
Importers can email the letter to CustomsTPsubmissions@sars.gov.za or hand it in at any customs office2.
The letter must say whether the price change is interim or final for that financial year1. It must also include the amended invoice, debit note or credit note from the supplier. An importer outside South Africa sends the letter through its registered agent.
What goes into the CVAC spreadsheet?
After the letter, the importer must ask SARS’s Trade Statistics department for the latest data on every affected bill of entry. The email address is tradestatistics@sars.gov.za2. The importer then has 30 calendar days after the letter to send its papers.
The main paper is the Customs Value Adjustment Calculation spreadsheet, or CVAC. It shows how the importer worked out the new customs value, duty and VAT1. SARS publishes a template on its website, but the importer must make sure its own figures are complete and correct.
The CVAC uses an adjustment factor. This is the percentage change applied to each affected line on a bill of entry2. It equals the total revised customs value minus the previous value, divided by the previous value, times 100.
For each shipment, the spreadsheet must list, among other items1:
- the importer’s name and customs client number
- the supplier’s name and the adjustment period
- the reference and movement reference numbers of each bill of entry
- the tariff heading, item number and value of the goods
- the revised customs value and the effect on duty and VAT
It ends with a declaration that the details are true and correct. Goods entered into a customs warehouse, a bonded store where duty is not yet paid, must stay out of the CVAC2. Those entries follow a separate correction process under section 40(3)(a)(i)(A).
Which other papers does SARS want?
Along with the CVAC, the importer must send its transfer-pricing policy and compensation calculation1. These show how the group sets its prices and makes changes. The importer must also send signed annual financial statements for the adjustment period, or the latest signed statements.
Papers sent with the CVAC spreadsheet
Where relevant, SARS also wants purchase and sale agreements and distribution agreements with all changes. It also asks for royalty and licence fee agreements2. Segmented financial data for each business segment is also on the list.
If some papers are not ready, the importer may ask the Commissioner for more time at the same CustomsTPsubmissions address1. If SARS approves, the importer must send them within the time set in the approval. The notice does not say how long such an extension may last.
When do importers pay extra duty or get a refund?
SARS must confirm in writing that it received the letter and papers2. It must then say in writing whether it accepts the CVAC. The importer must follow any further instructions for more information.
Extra duty owed or refund due
| Question | Importer owes SARS | SARS owes importer |
|---|---|---|
| Document | Form CEB01 from SARS | Voucher of correction per bill of entry |
| What it shows | Payment reference number | Refund amount and refund indicator |
| Who issues it | SARS | Importer, as refund request |
If money is owed, SARS issues a Customs and Excise Billing Declaration, form CEB011. The importer must pay within 14 days of being told the CVAC is accepted. Payment uses the payment reference number shown on the form.
If SARS owes money, the refund request goes in on a voucher of correction for each affected bill of entry2. The voucher must show the refund amount and a refund indicator. The adjustment and the voucher together count as the refund application.
Acceptance does not end the matter. SARS states that approval of a CVAC does not protect the importer from later audit findings, fines or penalties1.
How did the SARS transfer-pricing rules take shape?
SARS first published draft rules for public comment on 19 January 20243. At the time, it said the rules would give multinationals clarity on how to account for price changes on past customs declarations. The final notice came out more than two years later.
From draft to final rules
The rules sit apart from SARS’s new advance pricing agreements, or APAs. These are deals that fix transfer-pricing methods ahead of time for income tax. SARS’s APA guide says that its pilot, open from 1 September 2026, does not extend to customs and excise4.
So an income-tax pricing deal will not change what an importer owes at the border. Customs values still follow the Notice R.7900 steps.
Which SARS price notes fall under Notice R.7900?
The notice covers any amended invoice, debit note or credit note issued after 14 September 20262. Any bill of entry correction linked to such a note must follow the new process. SARS’s list of 2026 rule changes gives the same start date for R.79005.
Time limits after a price note, days
For each affected shipment, the supplier’s next price note now triggers the letter to SARS. The letter then starts a 30-day clock for the CVAC and supporting papers. The importer then has 14 days to pay once SARS accepts the spreadsheet.
Sources
- ↩ Customs and Excise Act, 1964: Amendment of Rules (Notice R.7900) https://www.sars.gov.za/legal-lsec-ce-ra-2026-13-r7900-gg-55355-ra-under-ss-40-41-and-120-relating-to-transfer-pricing-adjustments-dar279-11-september-2026/
- ↩ e5213c21-d213-46b1-addf-2c451d2827fb https://www.sars.gov.za/wp-content/uploads/RulesAmendments/Legal-LSec-CE-RA-2026-13-%E2%80%93-R7900-GG-55355-RA-under-ss-40-41-and-120-relating-to-transfer-pricing-adjustments-DAR279-11-September-2026.pdf
- ↩ 5bf1916b-86c0-4a5e-a480-60cec799d186 https://www.sars.gov.za/media-release/compliance-focus-for-transfer-pricing-adjustments/
- ↩ c91627db-cee5-4a64-9915-c824f539f67b https://www.sars.gov.za/wp-content/uploads/Ops/Guides/GEN-LBC-23-G01-Advance-Pricing-Agreement-External-Guide.pdf
- ↩ Rule Amendments 2026 (Notice R.7900, GG 55355) https://www.sars.gov.za/legal-counsel/secondary-legislation/rule-amendments/rule-amendments-2026/