International Tax


We provide advice in all spheres of South African and international tax, including trust and corporate taxes, exchange controls and transfer pricing.

General and corporate international tax services

We advise on:

  • all tax aspects of inbound and outbound investments;
  • finance structuring;
  • cross-border M&A and international trading operations;
  • the design and implementation of tax-optimised holdings;
  • operating and treasury structures;
  • cross-border financing arrangements; and
  • corporate tax issues associated with trading across borders.

Offshore fund formation and local and offshore trusts

Our fund formation services include advising on the:

  • most suitable legal entities to use, both onshore and offshore;
  • relationships between the fund and its managers, advisers and investment committees;
  • tax residence status of the various entities and their entitlement to tax treaty relief;
  • drafting of relevant agreements;
  • formation and structuring of offshore private equity and hedge funds;
  • taxation of offshore share schemes; and
  • taxation of local and offshore trusts.

Exchange control

Exchange control structuring and compliance is an integral part of cross-border tax structuring. We offer a wealth of experience in dealing with SARS and its authorised dealers regarding exchange control-related matters as they apply to both residents and non-residents. We assist corporate and individual clients to regularise past contraventions if necessary, as well as advising on the exchange control implications of proposed transactions.

Key Contacts
+27 21 431 7000