The Client runs a technology company providing software solutions across multiple industries and territories. The company is headed in South Africa and has a growing presence in the Middle East and Africa. The client wishes to optimise its tax structure, including the introduction of an international holding company to support its international growth while also maintaining compliance with the local tax laws, and to provide optimal flexibility for an ultimate disposal.
• Optimisation of the business structure for global expansion, identifying where and how to establish a suitable group holding company to facilitate future growth.
• Ensure compliance with relevant tax and legal regulations, in particular BEE considerations in South Africa.
To establish an offshore holding company in Mauritius in order to consolidate all international operations and a establish a trust that will hold the holding company.
To mitigate the Capital Gains Tax laws in South Africa, the shareholders would need to transfer the shares to the newly established holding company.
Ensure that the tax risks and compliance obligations are met by maintaining substantial management presence in the holding company jurisdiction.
• Improved BEE score which will allow for an increase in procurement spending within South Africa and ultimately strengthening the company’s BEE compliance.
• Successful Business Restructuring which allows for optimised global operations while ensuring compliance with both South African and international tax laws.
• Reduced tax burden where the company will significantly lower its effective corporate tax rate on international transactions.
• Long-term succession / exit planning where the structure enables the business to ensure a smooth transition of ownership.
English English 
French
Complete the fields below to download the guide by Dr Daniel N Erasmus.
Book a meeting with our Transfer Pricing team by completing the form below.
Thank you for your interest, please complete the form below to download the checklist pdf.
Thank you for your interest, please complete the form below to download the full pdf.
