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2016 Mazars: Taxation of International Transactions - Johannesburg
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When: 17 August 2016
From 08:30 until 13:30 (08h00 – 08h30 Arrival and registration )
Where: Mazars House
54 Glenhove Road
Melrose Estate
Johannesburg, Gauteng  2192
South Africa
Contact: Silvia Motaung

Online registration is closed.
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In an April 2016 media statement titled, 'Minister of Finance instructs Investigations into Offshore Holdings', Minister Gordhan made it clear that 'the world is systemically narrowing the scope for those who want to hide their offshore assets and avoid paying their taxes due to the South African fiscus'. The South African Revenue Service (SARS) has also 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.

There has been a marked increase in South Africans doing business and investing internationally, particularly in African countries. Across the African continent there has been a corresponding increase in the sophistication and enforcement of each African region's tax legislation.

South Africa is at the forefront of international work on exchange of information (EOI), including the new automatic EOI. From 2016, SARS will be collecting information and automatically exchange it on an annual basis from 2017. This means that all international transactions will be more visible to SARS enabling SARS to ensure taxpayer's are treating the transactions correctly for tax purposes.

The effect of all the above is that all taxpayers entering into international transactions must ensure a complete understanding of the corresponding tax obligations and risks.

Course Content
Join us as we address some of the specific tax provisions dealing, inter alia, with the issues raised above, including:

  • special Voluntary disclosure programme in respect of unauthorised offshore income
  • the Automatic exchange of Financial Account information


  • 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

  • Update on concept of 'permanent establishment', and new Interpretation note
  • Focus on provisions specific to tax treaties with major African trade partners.
  • Cashflow risks in respect of foreign withholding taxes

Brief overview of amended Controlled Foreign Company provisions

  • Application of section 9D
  • Disposal of interest in a Foreign company

Taxation of foreign income

  • Exemption for foreign dividends
  • Foreign trade income and losses
  • Exemption for foreign employment income

Double Tax Relief

  • Section 6quat, rebate and deduction
  • Documentation required to obtain rebate

Transfer pricing

  • Amended section 31 and tax consequences of application of the provision
  • New disclosure requirements in Company Tax Return
  • Base erosion and profit shifting (BEPS)
Who should attend
  • Owners of businesses involved in any international transactions
  • 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
  • Students studying International Taxes
Di Seccombe (B Com, LLB, LLM(Taxation))

Di Seccombe (B Com, LLB, LLM(Taxation)) 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. 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 for amongst others, the SA Institute of Tax Practitioners, the SA Institute of Professional Accountants and the UCT Graduate School of Business 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 and for Varsity College in Cape Town. 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.

This event and successful completion of the online assessment will secure 4 hours verifiable output CPD points/units.

Including the following professional bodies. (SAICA, CIMA, SAIPA, SAIBA, ACCA, FPI, CSSA, LSSA, FISA, ICBA, IAC, AAT)

Event Investment

Cost: R1 254.00 per delegate (incl. of VAT)

Click here to register


Payments & Cancellations

  • All payments must be made by EFT or by credit card, at least 3 working days before commencement of an event.
  • Kindly note that should payment not been received 2 days after the event, legal action will be taken
  • Proof of payment will be requested at registration, if payment at that point in time has not been reflected on SAIT's bank account.
  • Only written notice of cancellation will be recognised.
  • Conditions:
    • If the cancellation occurs more than 4 working days prior to the event no cancellation fee will be charged.
    • If the cancellation occurs less than 4 working days prior to the event a 100% cancellation fee will apply.
  • Delegates who book and fail to attend will be liable for the full event fee.
  • SAIT's liability in the case of an event being cancelled will be limited to a refund or credit of the event fee.

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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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