The Organisation for Economic Co-operation and Development (OECD) Action 3 in the Base Erosion and Profit Sharing Project (BEPS) outlines a roadmap on the formulation of the controlled foreign company rules. Countries can elect to adopt the recommendations or may even expand on them. South Africa (SA) has adopted the BEPS action 3 even though it is not a member state. The research report will examine whether section 9D (which codifies the South African controlled foreign companies rules) addresses the BEPS action 3 objectives and how some provisions of the section 9D interact with other parts South African tax legislation (transfer pricing) to address these objectives in the ever changing business environment. The methodology adopted in this report is of a qualitative, interpretive nature, based on a detailed interpretation and analysis of the literature. The literature review will mainly focus on the OECD documentation and South African statutes. The other sources are supporting material to help answer the main research question and to achieve the aim of the study
