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Tax Alert - Coronation controlled foreign company case

The ConCourt held that the Dublin based business operation of Coronation Global Fund Managers (Ireland) Ltd (“CGFM”) did indeed qualify as a “foreign business establishment” (“FBE”), for the purposes of South Africa’s (“SA”) controlled foreign company (“CFC”) rules, overturning an earlier SCA decision.

The SCA had held that CGFM’s core business operations included actual investment management and that the company’s decision to outsource investment management disqualified it from the substance requirements in the FBE definition. The ConCourt , however, held that CGFM’s stated business of fund management was not only to be distinguished from investment management but also was, in fact, the company’s core business. The SCA had thus erred in denying the exemption.


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Chimwemwe Kainja

Chimwemwe Kainja

Senior Manager, PwC South Africa

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