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International Tax Seminar 2012 - Di Seccombe - Cape Town
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When: Tuesday, 19 June 2012
09:00 - 13:00 (Registration from 08:15)
Where: The Commodore Hotel
Portswood Road
Portswood Square
Cape Town, Western Cape 
South Africa
Contact: Moniqua Janse Van Vuuren

Online registration is closed.
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SARS Commissioner Oupa Magashula this week told parliament's finance committee that it had "detected an increase in the use of cross-border structuring and transfer pricing manipulations by businesses to unfairly and illegally reduce their local tax liabilities." He said evading tax in African countries has been widespread due to nations failing to pick up on tactics used by businesses to pay less tax.

There has been a marked increase in South Africans doing business in and investing in other African countries. Across the African continent there has been a corresponding increase in the sophistication and enforcement of each African region's tax legislation. SARS, the African Union and other stakeholders have identified the need for a renewed focus on transfer pricing legislation, tax treaties and exchange of information agreements.

The International community as a whole 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.

2011 saw major amendments to the tax legislation in respect of the taxation of foreign dividends, payment of local dividends and interest to non-residents and controlled foreign companies.

Course content:

Join us for a detailed discussion and review of the specific tax provisions dealing, inter alia, with the issues raised above, including:
  • "Residence"
    • When is a taxpayer "resident" or "non-resident"?
    • New section 9 source provisions
    • South African withholding taxes on the payment of dividends, interest, royalties
  • Double tax agreements
    • Focus on provisions specific to tax treaties with major African trade partners for example Nigeria, Angola, Uganda, Zambia
    • Update on concept of a permanent establishment
  • Amended Controlled Foreign Company and Headquarter Company provisions
    • Application of section 9D
    • Disposal of interest in a Foreign company
    • Tax benefits of a Headquarter Company
  • Taxation of foreign income
    • New exemption for Foreign dividends
    • Foreign trade income and losses
  • Double Tax Relief
    • Section 6quat and new section 6quin rebates and deduction for Foreign taxes
  • Transfer pricing
    • Amended section 31 and tax consequences of application of the provision
    • What does this mean in the African context

Who should attend

  • Corporate financiers and persons involved in financial planning and advisory services
  • Tax specialists
  • Practicing accountants and lawyers,
  • In-house tax managers and advisors
  • Financial directors and managers and business owners

About the presenter

Di Seccombe (B Com, LLB, LLM (Taxation)

Di Seccombe is an admitted attorney with a Masters degree in taxation and has been involved in tax for over 10 years. Di is currently the National Head of Tax training and Presentations with Mazars and in this capacity provides tax training to Mazars partners, staff and clients on a national basis. Di also consults on Income Tax matters including, Corporate, Individual and International tax as well as VAT.

Di presents tax seminars on a national basis, focusing on general as well as specialised tax topics. Di still lectures part time for the National School of Accounting to assist up and coming CA's with passing the UNISA CTA (Hons) programme.

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 to attendees ranging from JSE Corporate advisers to smaller tax practitioners and is a popular lecturer amongst her students. Di's primary focus in any presentation is that attendees find the material relevant and presented in an understandable and accessible manner.


Your attendance will also give you 4 valuable hours of CPD.




Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.

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