Regan van Rooy is a boutique international tax and structuring firm, focussing on Africa. Established in 2016, our people provide quality, pragmatic advice and services on all taxation and structuring aspects for inbound and outbound African clients. We have offices in South Africa and Mauritius and have a deep focus on the trade corridor between the two countries. We also have an office in Ireland which plays a key role in our African-outbound work, as Ireland is to Europe what Mauritius is to Africa.

Structuring is both an art and a science – this is our specialist area of expertise. How you structure your business is a critical imperative as you grow, particularly as you enter new jurisdictions. The right structure will protect your assets, improve your currency position, support your business operations, facilitate future business expansion or shareholding changes, minimise exchange control restrictions, and optimise your overall tax rate.

Trying to unscramble a sub-optimal structure entered into in haste or without full consideration of relevant facts is complex and expensive, so it’s important to plan upfront. We will help you do it once and do it right. We can help you as follows:

• Optimising your global and intermediary holding structures;
• Optimising your treasury and funding structures;
• Planning capital injections and extractions;
• Identifying optimal corporate vehicles and structuring intra-group transactions;
• Optimising global taxes at both group and shareholder level;
• Optimising your structures for both operational tax and tax on exit.

We can advise on any taxation issue facing your business in South Africa, Mauritius, and across the African continent, with a focus on cross-border tax issues. Whether you are looking at how best to enter a new jurisdiction, resolving a Revenue audit, optimising your global structure, or reducing your overall tax charge, we can help you.

Our team are specialists in the key international tax areas of double taxation agreements, residence, transfer pricing, controlled foreign companies, expatriate taxation, withholding taxes, and are seasoned in the particular challenges of tax in the African context.

As transfer pricing is becoming more and more integrated with international tax frameworks, we have deep transfer pricing expertise. We consider transfer pricing not as a compliance requirement, but as the critical cornerstone from which to build a successful structure.  How your group entities transact with each other is the real structuring question, and this is why any successful international structure must be under-pinned by an optimised transfer pricing framework.

A core part of today’s international tax environment is transfer pricing. This is typically the key area of focus for tax authorities globally, with complex and rapidly changing rules and documentation requirements. We can help you navigate the minefield that is transfer pricing in Africa, we offer the full suite of transfer pricing services, including:

• Providing transfer pricing strategic advice, planning, and policy drafting
• Drafting transfer pricing risk assessments
• Drafting and planning Advanced Pricing Agreements
• Transfer pricing reviews
• Drafting of all transfer pricing documentation, in order to ensure compliance with the applicable revenue authorities, including:
  • Master File
  • Local Files and all supporting documentation
  • Country-by-country reporting
• Drafting of benchmarking studies and reports
• Controversy and dispute resolution

Do you need an experienced tax specialist who is available to help you right now?
Do you have a gap in your tax team you need to plug?
Do you have a short-term crunch period where you need an extra steady pair of hands?

We have a panel of experts offering experienced, pragmatic, in-sourced solutions and services in the following key technical areas:

• Corporate tax compliance
• Revenue audits
• Transfer pricing
• CFC compliance
• Employee or expatriate taxes
• Withholding taxes
• VAT compliance
• Project management / implementation
• SARB compliance

We can parachute in specialist help as and when you need. We will in-source to fill gaps for staff who are on short or longer term leave, where a new hire is being recruited, or to up-skill your existing staff. We can also help you fill gaps over crunch periods, e.g., during year-end audits, revenue queries, start-ups or expansions, company restructurings, compliance with new legislation, implementing new processes, compliance deadlines, etc.

Our people are available on tap to provide services, for as short or as long as you need.

How you structure your business is a critical question as you expand globally.  The right structure will protect your assets, improve your currency position, support your business operations, facilitate future business expansion and changes, and optimise your overall tax rate. Trying to unscramble a sub-optimal structure entered into in haste or without full consideration of relevant facts is complex and expensive, so it’s important to plan upfront. Structuring is both a science and an art – this is our specialist area of expertise.