The taxation of cross-border transactions and foreign entities is complex and requires specialised tax knowledge and skills that include the working knowledge of foreign taxes and Double Taxation Agreements between South Africa and contracting countries, in which our clients operate.

We work closely with our offices in the African region and globally, where applicable, to provide relevant cross-border transaction advice.

Our services includes the following:

  • Advising on tax implications of financing agreements entered into by related entities and non-related entities in different countries
  • Advising on and reviewing of effective management risks
  • Advising on tax implications of cross-border transactions
  • Advising on controlled foreign company risks
  • Advising on new group structures
  • Reviewing of efficiency of existing group structures
  • Advising on and reviewing of tax nexus risks
  • Drafting and reviewing of existing transfer pricing policy documentation and implementation
  • Performing benchmarking studies
  • Advising on optimum pricing of intercompany transactions ​
  • Preparing country-by-country reports​
  • Submission of required documentation to revenue authorities ​
  • Defending/ supporting clients on transfer pricing audits ​
  • Preparing advanced pricing agreement requests