INTERNATIONAL TAX TRANSACTIONS
Presenter : Di Seccombe (Bcom, LLB, LLM(Taxation)
Di Seccombe has been involved in tax for the past 10 years. She is an admitted attorney with a Masters degree in taxation. Di is currently a senior tax manager with Mazars in Cape Town and lectures part time on the UNISA CTA programme to assist up and coming CA's. Di started her tax career as a full time academic with the University of KwaZulu-Natal before moving into practice. She has presented numerous tax seminars with great success and is a popular lecturer amongst her students, as her primary focus in any presentation is that attendees find the material presented in an understandable and accessible manner.
South Africa has become a fully-fledged member of the international economy. Many South Africans invest and carry on trading activities offshore and correspondingly, many non-residents trade and invest in South Africa.
The international community is succeeding in its efforts to end bank secrecy, and this has resulted in greater access to information regarding international transactions being enjoyed by SARS both domestically and internationally. The result is that taxpayers have to have a firm grasp of the tax consequences of international transactions.
Join us for a detailed look at the most common international transactions and their tax consequences, including :
· When is a taxpayer "resident" or "non-resident"?
· South African withholding taxes for non-residents
· Taxation of foreign services: Can a non-resident be an independent contractor for PAYE purposes?
Controlled Foreign Companies and Headquarter Companies
· Application of section 9D and elections
· Disposal of interest in a Foreign company
· Tax benefits of a Headquarter Company
Taxation of foreign income
· Foreign interest and Foreign dividends - relevent exemptions
· Deduction of interest expenses incurred to produce foreign dividends
· Foreign trade income and losses
· Section 6quat - Rebate and deduction for Foreign taxes
· Double tax agreements
· Tax consequences of movement of assets into offshore trust
· Deemed accrual of offshore trust income to SA donors and beneficiaries
Transfer pricing and thin capitalisation
· Where we are and where we are going
Who Should Attend
Corporate financiers and persons involved in financial planning and advisory services / Tax specialists / Practising accountants and lawyers / In-house tax managers and advisors / Financial directors and managers and business owners
Attendance at this seminar will secure 4 hours verifiable CPD points including other professional bodies (SAICA, SAIPA, SAIBA, ACCA, IAC, ICB, FPI, ACIS, LSSA, FISA)