CROSS BORDER TAXATION

SIMPLIFIED TAX SOLUTIONS

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 distinct reporting and compliance challenges. 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.

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Our diverse team has advised many clients 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.

INDIVIDUALS

We offer specialised services for South African expatriates working abroad, as well as foreign employees working in South Africa.

Where you cannot formally financially emigrate, the double tax agreement tie-breaker clause is an equally legitimate route to break residency.

CORPORATES

Enterprises looking to expand into global markets to have an efficient corporate structure from inception.

We remove barriers created by silos and delivers flexible end-to-end solutions by providing an extensive range of tax services and guidance on the most tax-efficient way to structure your business from the outset.

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. SARS system is leaving no stone unturned, and see expatriates as well as individuals as an easy target.

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INVESTING IN AFRICA AND EXCHANGE CONTROL

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 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 guide how to negotiate the obstacles associated with an investment in the African continent and to ensure that your business is conducted profitably.

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 a transaction to prevent blocked transactions and the imposition of penalties.

SERVICE OFFERING

Conducting functional analysis to establish the functions and risks undertaken by the company in cross-border transactions

Transfer pricing policies, reviewing and implementation thereof

Compliance with document retention and filing

Responding to SARS audits in a timeous manner

Drafting and reviewing intercompany agreements

Expatriate Tax Compliance

HERE’S WHAT OUR CLIENTS HAVE TO SAY:

I definitely recommend Tax Consulting South Africa. They are professional, helpful and knowledgeable. I could not have got through the process without them. I really appreciate their 5 star service and I will be telling my friends and family about my excellent experience with them.

Nicole Howard

Excellent, efficient and professional service! Also, was well supported when dealing wit a sluggish financial institution to expedite the process. They went the extra mile – Thanks.

Werner Kaiser

Tax Consulting has been helping me with a serious problem that I had with SARS with my company. They have been truly excellent all round in terms of results, friendliness, swiftness of work, professionalism, pricing. We aren’t 100% complete yet, but thus far are getting great results. I would (and have already) recommend them to anyone for tax services, and in particular if you have a more complicated tax issue to resolve.

Andreas van Wyk

The most wonderful bunch of people one can meet! They are all totally helpful and were always willing to support and help me. They came through on a tough assignment and achieved every goal we set out to achieve. Special thanks to Ralitza and Jashwin. Please continue to flourish and prosper!

Ian Hammond

We found the premises to be well appointed and the staff to be professional, efficient and friendly.

Gugu Gumede

The service and the commitment to my case was well taken care of. Much appreciated.

Gerald Sealetsa

MEET OUR CROSS-BORDER TAXATION SPECIALISTS

Darren Britz
Partner and Head of Tax Legal
(Admitted Attorney of the High Court of South Africa)

Jashwin Baijoo

Associate Director
Head of Strategic Engagement & Compliance
Admitted Attorney, LLB, LLM (Tax)
Master Tax Practitioner (SAIT)
Professional Tax Specialist (SA)
SAIPA Tax Committee Member

Delano Abdoll
Legal Manager: Cross-Border Taxation

Richan Schwellnus
Tax Attorney
Admitted Attorney, BCom (Hons), LLB
General Tax Practitioner (SA)™ (SAIT)

Micaela Paschini
Team Lead: Tax Legal

IN THE NEWS

NEWS | SARS IS AWARE OF YOUR OFFSHORE ASSETS

The days where SARS shuts its eyes to taxpayers’ offshore holdings are thing of the past. SARS is finally utilising the Automatic Exchange of Information regime to pin down taxpayers who have not disclosed their offshore interests and numerous taxpayers have already received some alarming notices to this effect.

NEWS | BREAKING INTO AFRICA: HOW MULTI-NATIONALS MAXIMISE PARTNER NETWORKS TO EXPAND THEIR FOOTPRINT

Many African countries have recorded excellent gross domestic product (GDP) rates in excess of six percent in recent years and with their vastly youthful populations are attracting myriad multi-national firms that foresee these economies as presenting the next massive global growth opportunity.