Deemed loans under transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... seen as a dividend declared on 1 January 2015 Authors: Okkie Kellerman, Jens Brodbeck and Arnaaz Camay (ENSafrica) South African taxpayers who