The taxation of cross-border transactions and multinational entities is one of the most complex aspects of tax law. Internationally mobile employees and multinational entities face a distinct reporting and compliance challenge. The challenge is compounded by the concerted enforcement efforts by revenue authorities across the globe.

With the expansion of operations into international markets comes the demand for more rigorous management of one’s tax affairs. Tax Consulting offers a multi-faceted service line in dealing with international tax matters.

How can Tax Consulting help you?

Residency

Our firm offers advice on general cross-border taxation issues such as residency of companies and individuals, permanent establishments, controlled foreign companies, double tax agreements and foreign tax credits.

Internationally Mobile Employees

We offer a full range of tax services for expatriates working outside South Africa as well as for foreign employees working in South Africa. Click here to see expatriate tax services for individuals.

Transfer pricing

Transfer pricing has become an important focus area for revenue authorities in the taxation of multinational entities. SARS is no different and is currently involved in various audits of large multinationals. Transfer pricing risk must be managed carefully to withstand scrutiny from revenue authorities and to prevent being subject to transfer pricing adjustments.

Our services include:

  • Conducting functional analysis to establish the functions and risks undertaken by the company in cross-border transactions
  • Preparing transfer pricing policies and implementation thereof
  • Reviewing transfer pricing policies
  • Compliance with document retention and filing
  • Responding to SARS audits
  • Drafting and reviewing intercompany agreements

Advising on group structures

It is imperative for enterprises looking to expand into global markets to have an efficient corporate structure from inception. Tax Consulting provides guidance on the most tax efficient way to structure your business from the outset.

Investing in Africa

With some of the fastest growing economies, Africa holds many innumerable attractive investment opportunities. Our firm has assisted many clients to set up and expand their businesses in various African jurisdictions. From a tax perspective issues such as withholding taxes and repatriation of profits is a key consideration when doing business in Africa. Our firm is the ideal partner to provide guidance on how to negotiate the obstacles associated with investment in the African continent and to ensure that your business is conducted profitably.

Exchange control

Exchange control regulates the flow of capital into and out of South Africa. Exchange control regulations have moved to a less restrictive regime, but it is important to be cognizant of the applicable exchange control regulations and required approvals when planning capital movements into and out of South Africa. It is important to determine what type of approval must be sought before entering into a transaction in order to prevent blocked transactions and imposition of penalties.

Speak to our Cross Border Taxation Specialist

Jean du Toit – Admitted Attorney of the High Court of South Africa