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International Tax

International Tax

With a primary focus on South African and Mauritian tax law from an international perspective, and through associated service providers, we advise on tax laws in Seychelles, Malta, the USA, Dubai, and sub-Saharan countries. Services cover employees' tax, income tax, withholding taxes, CGT, dividend tax, expatriate taxes, anti-avoidance, residency rules, incentives, compliance, and Double Taxation Agreements.

How We Can Help

Our team of experienced tax attorneys provides comprehensive assistance in all aspects of international tax. We work closely with our clients to understand their unique circumstances and develop tailored strategies that protect their interests while ensuring compliance with all applicable tax laws and regulations.

Our Approach

  • Thorough analysis of your specific situation and requirements
  • Strategic advice tailored to achieve your objectives
  • Clear communication throughout the process
  • Experienced representation in dealings with SARS and other authorities

Need assistance with international tax?

Our team of specialists is ready to help.

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Other International Tax Services

International Tax Structuring

We guide clients on offshore structuring for import-export, trading, IP, asset holding, and investment purposes. Benefits include tax savings, asset protection, reduced red tape, and enhanced confidentiality through trusts and nominee directors.

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Approval for International Transfer (TCS-AIT)

Transferring large amounts of foreign currency now requires SARS TCS-AIT verification. Our team assists with compliance and documentation to obtain approval, whether for residents transferring funds annually or non-residents post-emigration.

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Transfer Pricing

Transfer pricing refers to the internal price tags companies set for goods and services traded between their subsidiaries in different countries. This practice is particularly relevant for Multinational Enterprises (MNEs) with a global presence. While transfer pricing offers flexibility for managing internal operations, it's crucial to ensure these prices are set fairly. There's a potential risk of companies manipulating these prices to shift profits to countries with lower tax rates as identified in the OECD BEPS Actions 8 - 10. The OECD Multilateral Instrument contains specific provisions that seek to prevent this form of base erosion and there are many examples of domesticated specific anti-avoidance provisions around the world's jurisdictions. In SA, if the Transfer Price is at variance with the "Arm's Length Price", SARS is empowered to invoke section 31 of the Income Tax Act 58 of 1962 and correct what it considers to be a serious erosion of the SA Tax Base. Should this occur, depending on the circumstances, penalties (to various degrees) and interest will be levied. The cost of non-compliance is therefore steep. It should be noted that the determination of an "arm's length price" is not a simple task and there are different methodologies to be applied in different commercial settings in developing the Transfer Pricing Policy for an MNE. As such, parties to a cross-border transaction can easily fall foul of the arm's length principle without the intention to erode any tax base. The guidance of a Transfer Pricing expert should therefore be sought when parties (especially connected persons) conduct cross-border transactions. It is also recommended for MNEs or similar cross-border connected structures to have a Tax Risk Committee that conducts ongoing compliance monitoring.

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+27 (0) 21 569 6050

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info@trmlaw.co.za

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Cape Town, South Africa