International Tax & Exchange Control

​We advise on the local and foreign tax implications of inbound and outbound transactions. We have deep specialist expertise in advising on cross-border arrangements, including group treasury and IP-related structures as well as cross-border mergers and acquisitions and international trading operations.

Our international tax offering includes in-depth expertise tax issues across Africa. Through our alliance with Linklaters and our network of leading African tax advisers, we can assist clients with all pan-African tax-related matters. We have an established track record of project managing the largest and most complex cross-border transactions on the continent. In our years of experience working in Africa, there is no 'one-size-fits-all' tax structure for African investments. However, with a sound understanding of the tax systems of the countries involved, and careful tax planning, it is possible to reduce the tax cost of doing business in Africa.

Our international tax offering includes:

  • designing and implementing appropriate investment structures;
  • minimising tax leakage where feasible on cross-border cash flows through the design and implementation of appropriate and tax-compliant structures;
  • managing the tax implications of exiting particular investments; and
  • assisting with company income taxes and withholding taxes.

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

Also related to international tax, we assist clients with a number of transfer pricing related matters, including:

  • designing proposed transactions and acquisitions to ensure that these are both tax efficient and low risk from a transfer pricing perspective;
  • resolving transfer pricing disputes with tax authorities; and
  • evaluating whether transactions entered into between connected persons are at arm's length.