Under the heading of Base Erosion and Profit Shifting, it has been stated that Government will propose amendments to the tax legislation to improve transfer pricing documentation and reporting. Currently, transfer pricing legislation does not require a taxpayer to have a written transfer pricing policy. Should that become a requirement, it would inevitably lead to increased costs of compliance. A number of related questions arise, such as which databases of benchmark data would be appropriate and whether SARS will introduce an advance pricing agreement system (as has been done in other African countries already) to give taxpayers some certainty on their transactions and thereby allow them to focus on their primary goal of running and growing their businesses without being overburdened by additional administration.