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Digital and Analytics
We have developed distinctive capabilities in digital advisory and data analytics that are key to the success of dynamic organisations.
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Business Consulting
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Corporate Finance & Restructuring
We combine our insights and experience to provide a comprehensive range of advisory and corporate finance and restructuring solutions.
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Internal Audit
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Our service is focused on enabling broader risk coverage and proactive management of risks for the achievement of organisational strategy.
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Business Process Solutions
We work with a multitude of organizations to improve their finance function efficiency, reduce costs associated with business processes and provide a complete solution to the challenge faced by South African organizations.
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Our aim is to protect shareholder value by providing Assurance and Advisory services on change portfolios and large-scale programmes to assist organisations.
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Forensic Services
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We help clients to navigate the complexities and provide you with robust independent assurance that your IT risks, key management priorities and core systems are being appropriately managed.
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SNG ARGEN
We have a dynamic actuarial team set to assist businesses to comply with the audit standards where actuarial services are required.
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General Audit
We provide a sound statutory audit of financial statements specialising in both listed entities and state-owned organisations.
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Financial Services Group (FSG)
The Financial Services Group (FSG) offers specialised audit and advisory solutions to the banking, treasury and financial services sectors.
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Technical Excellence
We have a well-established specialized technical division, with in-depth, local and international knowledge and experience, which consists of three units namely; Accounting, Audit and Sustainability reporting.
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Corporate Tax
We offer your business access to a global network of tax specialists in over 130 countries with extensive corporate tax technical skills to provide meaningful advice and adding value to your organization.
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Value-Added Tax
We can manage your overall exposure to indirect taxes, guide you through complex South African Value-Added Tax (VAT) legislation.
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Global Mobility
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International Tax & Transfer Pricing
Our team is ideally suited to serve large multinationals and other global companies that need on the ground expertise in multiple jurisdictions, given our extensive network of offices around the globe.
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Specific Focus Areas
We have a team of dedicated tax specialists with deep knowledge to bring practical and cost-effective tax solutions to our clients and assist entities operating within these sectors to effectively manage their tax needs.
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Business Consulting
We provide fit-for-purpose solutions to address major challenges the Education sector faces by supporting our clients.
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Employees’ Tax Services
Its important to ensure that the institution complies with the tax legislation and that all payroll records are accurate and complete.
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Programme Assurance & Advisory
The need for sound project management and effective solution delivery gives you the edge in competitive markets.
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Forensic Services
Fraud detection review and forensic investigation for Higher Education
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Digital and Analytics
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Cyber Security Services
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SDG Impact Standards Training Course
Details of the Case
Citibank US and Citibank SA entered into an agreement concerning the secondment of employees to Citibank SA, with the agreement stating that the seconded employees were not employees of Citibank SA.
Arguments Presented
Citibank SA argued that the seconded employees were its employees, while SARS argued that Citibank SA was not the employer of the seconded employees and should be liable for VAT on imported services.
Court's Findings
The court found that Citibank SA could not show that it was the employer of the seconded employees and that the payments made to the individuals did not constitute "remuneration" within the meaning contemplated in the definition of enterprise in the VAT Act.
Key Lessons
The case highlights the importance of carefully considering the wording used in secondment agreements, especially where the secondment is between an RSA-based and a foreign party. All tax implications must be assessed upfront before the agreements are concluded to ensure an efficient tax position is adopted.
Conclusion
Legal decisions are based on what the parties involved intended, as written in legal provisions. Citibank SA can't argue against these provisions, which clearly state the intention of the parties regarding employees who are seconded. They cannot claim to have paid salaries to those who weren't their employees because they are not an employer. However, Citibank US's payments are considered fees for services rendered and are subject to VAT under the reverse charge mechanism.
Who is the employer for VAT purposes? SARS vs Citibank