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Overview
With today’s global economy, businesses are exposed to fast changing legislation, regulations and tax environments with operations, supply chains and customers across the globe. It’s vital to manage and respond to these developments in an agile way.
Our international tax team, based in Johannesburg and Cape Town, supported by an extensive African and global network, is able to provide fit for purpose solutions and support in managing your global tax structuring and compliance obligations effectively and responsibly, regardless of the size of your operations. We work closely with our colleagues in other tax competencies such as transfer pricing, VAT, employees tax, etc. to ensure a seamless tax service.
How we can add value
- Expanding outside of South Africa
- Cross-border value-chain management
- Investing into South Africa
- South African exchange controls
- Mergers and acquisitions
Expanding outside of South Africa
When businesses expand or invest outside of South Africa, they are exposed to unfamiliar in-country laws and practices.
Supported by our African and global network, we act as a single point of contact to assist you throughout the investment cycle - from setting up your new business or structuring an acquisition, determining the appropriate mix of debt and equity financing, managing ongoing tax accounting and compliance obligations, to structuring an eventual exit.
PwC provides a strategic and holistic integrated approach to global tax planning, where all of the following fundamental components can be addressed, subject to the commercial drivers of the business:
- Profit Alignment;
- Attribute Management; and
- Treasury Management.
We are the largest provider of professional services in Africa, with offices in 34 countries and close to 9,000 people working together in integrated teams across the continent.
Cross-border value-chain management
Cross-border value chain management can be complex, with numerous aspects to consider.
Our international tax professionals have the resources, experience and local competencies to assist companies in addressing these needs. We ensure that we blend the appropriate expertise, including corporate tax, exchange controls and indirect tax, to assist in simplifying the issues and supporting and optimising your value-chain management.
Investing into South Africa
The continuously changing South African tax law and strict exchange control regulations overlaid with evolving international best practices in the interpretation of tax treaties, have an impact on foreign-based multi-national corporations looking to penetrate the South African market.
PwC’s inbound tax advisory services are well placed to assist with guiding multi-national corporations through these complex issues, including but not limited to:
- Advising whether a foreign-based business is at risk of triggering a South African tax presence;
- Ensuring that the corporate, transactional and financing aspects of an investment are aligned with the tax outcomes;
- Ensuring that the relevant statutory requirements and company law compliance obligations are met; and
- Considering the impact of the repatriation or redeployment of funds from or to South Africa.
South African exchange controls
South Africa has strict exchange control regulations, which govern the flow of funds into and out of the country. Understanding and complying with these regulations is important for any cross-border transaction (excluding transactions within the Common Monetary Area of South Africa, Namibia, Lesotho and Eswatini).
Earlier in 2020, as part of the 2020 Budget Review, it was indicated that the existing exchange control rules would be reviewed and that the exchange control regime would be replaced by a new capital flow management framework in terms of which a number of changes to the existing regulations would be made. It is important to understand how this may impact any proposed future (structuring or other) cross-border transactions.
Contact our International Tax Services Department for more information and assistance with the above.
Mergers and acquisitions
PwC’s International Tax team advises listed and private groups on cross-border buying, selling, merging and restructuring businesses, companies and groups. The tax team together with PwC’s Advisory M&A team (who are a registered JSE sponsor and regularly provide advice to the listed exchange regulatory environment) provide an integrated service-offering from initial diligence and structuring assistance to implementation and post-deal assistance.
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