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2018 Cross-border Considerations for the Global Client
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Registration: 7h30 – 8h00

Welcome and opening address: 8h15 – 8h30

Presented by

Professor Keith Engel, SAIT’s Chief Executive

As part of Keith’s core duties managing the South African Institute of Tax Professionals, he is heavily engaged in tax at a policy, legislative and interpretative level (e.g., with National Treasury, Parliament, SARS, the Davis Tax Committee and the private sector).

His role also includes presentations and participation in regional African tax issues. Outside of the Institute, he regularly teaches at the University of Johannesburg and is an honorary adjunct professor at the University of Cape Town, North Western University and Rhodes University. Keith is well known for his leading role at National Treasury in the formulation of tax legislation from 2000 to 2013.


Andrew Wellsted, Tax Executive at RM Partners

Andrew is a highly regarded tax practitioner operating primarily in South Africa and Africa. He is a lawyer by training and specialises in tax and general transactional legal issues in these jurisdictions. He is a tax executive at RM partners, a recent entrant into the legal, tax and general commercial transactional advisory space. He advises on most tax matters relevant to the firm’s corporate client base and has a wealth of experience in:

  • Banking transactions
  • General corporate transactions, including merges and restructures
  • Appropriate structures for high net worth clients, both locally and abroad
  • Tax disputes
  • Cross-border transactions

He is part of the firm’s specialised exchange control team and is recognised for developing a broad range of innovative solutions to manage regulatory challenges faced by clients. He was the head of tax for South Africa at one of the large international firms until March 2018. He has written numerous articles and has been included in several international lawyer-ranking publications, most recently in band 2 for tax practitioners in Chambers 2018.

Automatic exchange of financial information between tax authorities: 8h30 – 9h45


  • An update on the automatic sharing of financial information between tax authorities and the impact of the sharing of information on individuals and entities
  • A general update on reporting duties: Africa and the world
  • Who is responsible for reporting?
  • OECD rules vs CRS avoidance strategies: What does this mean to an advisor or financial institution?
  • The consequences of non-compliance
  • Reality check: Will tax authorities collect more taxes because of the exchange of information or do you think taxpayers are generally compliant?

Presented by

Justine van Wyk, Group Tax: FATCA and CRS Specialist at FirstRand Bank Ltd

With 18 years’ experience in banking, Justine’s knowledge expands over various departments, ranging from approximately 8 years in customer-facing, supervisory positions, back office credit and securities, and 10 years in the regulatory project environment. Justine’s current position at FirstRand Group Tax is stemmed from the knowledge she gained from her previous positions as:

  -  Group program manager for the implementation of the Foreign Account Tax Compliance Act (FATCA) and the international standard known as the Common Reporting Standard (CRS)
  -  Acting lead for the Banking Association South Africa, including managing the awareness of FATCA and further engagement into Africa

Coffee break: 9h45 – 10h00

Global planning challenges and opportunities in a highly regulated and uncertain world: 10h00 – 11h30


  • Data sharing, Paradise Papers, ultimate beneficial owner registers, unexplained wealth orders, adviser penalties: What have we learned from the past 12 months and what's next on the global transparency agenda?
  • How can a South African tax resident manage their economic and political risk by holding offshore assets without falling foul of the situs rules?
  • Are offshore investments still worth the hassle in the CRS era?
  • Do trusts still have a role as a tax planning vehicle or are their days numbered?
  • Globally mobile families: Where does tax fit into citizenship and residency planning? What special considerations must be made before emigrating to the US or obtaining a US green card?
  • What's on the agenda for the UK's non-dom regime?
  • Is the UK still a destination of choice with Brexit and poor weather when countries in sunnier climes have equally attractive programmes for temporary residents?
  • Trump's tax reforms: Has the biggest overhaul of tax legislation in a generation made the US a destination of choice for offshore investors? Was the 'big, beautiful tax cut' actually a white elephant?

Presented by

Rachel Bentley, Director in PwC’s Private Client tax team

Rachel joined PwC in Tokyo, Japan in 2002 and has worked with the firm successfully for 16 years in London, New York, Cape Town, Tokyo and Honolulu. She specialises in providing cross-border tax services to wealthy individuals and families with complex international tax and legal situations. Her particular focus is US taxation but she also has a working knowledge of the UK and Japanese individual tax systems.

In addition to her individual income tax expertise, Rachel is also comfortable with the tax treatment of trusts, estates and closely held entities set up for commercial and philanthropic purposes. She regularly advises on the impact of data sharing regimes such as CRS and FATCA as well as the broader transparency agenda. Rachel's client base consists of internationally mobile families, entrepreneurs and executives. She supports her clients effectively by working closely with family office representatives and other intermediaries.

At present, she is focused on developing PwC’s private wealth offering across the PwC Africa Network. In 2016 and 2017, Rachel was named by Spear's magazine as one of the UK's top recommended tax accountants. Outside of her day job Rachel is a trustee of Fair Money Advice, a charity focusing on supporting the financially excluded and highly indebted.

Businesses and families, preserve the legacy and minimise the impact of real and perceived challenges: 11h30 – 12h45


How should advisors assist families in developing comprehensive solutions? The below areas of relevance are considered:

  • Family governance
  • Succession planning
  • Family business strategy
  • Compliance and reputational risk factors and reporting
  • Private wealth management
  • Family office and philanthropy

Presented by

Catharina Prym, Family Business Specialist at PwC

Catharina is specialised in owner strategy consulting. She is a 15th generation member of one of the oldest entrepreneurial dynasties in the world: the Prym Family, which was founded in 1530.

Today’s Prym Group has its head office in Germany and is a leading, worldwide supplier of creative sewing products, fashion accessories and mechatronics with production facilities around the globe. Catharina has been closely involved in the family business from a young age and was the first in her generation to be on the shareholders board. Due to her contributions she was honored with the Top Family Business Rising Star Award at the European Families in Business Awards 2015.

She studied family businesses at Europe’s first entrepreneurial University Witten/Herdecke, then moved on to learn her craft in Germany’s leading consulting boutique for Owner Strategy, INTES. Here, PwC’s unique consulting method was originally developed before PwC incorporated the know-how to make it available worldwide. In 2016 Catharina joined PwC to assist the firm with establishing its Family Business Service in South Africa. She works as a consultant for renowned, multigenerational family businesses in Europe and Africa.

Lunch 12h45 – 13h30

Planning for successful individuals and entrepreneurial families with Middle Eastern exposure: 13h30 – 14h10


  • Tax and immigration practices with a specific focus on advising successful individuals and entrepreneurial families with Middle Eastern exposure
  • Strategies that should be considered for wealth protection1
  • Implementing inter-generational wealth transfer strategies
  • Structuring operational assets and global wealth
  • Planning for mobile families with a South African link

Presented by

Yann Mrazek, Managing Partner of M/HQ, Dubai

Yann chiefly focuses on private wealth, tax and immigration practice. He has vast experience advising successful individuals and entrepreneurial families with Middle Eastern exposure on implementing inter-generational wealth transfer strategies and structuring their operational assets and global wealth.

He is the Chair of STEP Arabia and the sole Attorney in the Middle East referenced on the Who’s Who Legal: Private Client lists.

Time: 14h10 - 14h30


A brief refresher and update on Mauritius, considering that winds of change are certainly headed their way. How are they weathering the storm? Despite all of this and the changes which will need to happen, Mauritius is also very reliant on the sector for both contribution to GDP and as an important business sector employer. Possible solutions to address the challenges will be to continue to include making it attractive, keeping the “doing business easy” and manoeuvring within the confines of global changes.

Brendon Jones, CEO of Adansonia Holdings Limited, Mauritius

Brendon is the CEO of Adansonia Holdings Limited, a diversified financial services company offering corporate services to people doing business in Africa, based in Mauritius. With 11 years Mauritian experience, Brendon has built-up a valuable business network of clients, attorneys, accountants and service providers across a number of sub-Saharan countries. The Adansonia Group currently provides several value-add solutions to a range of corporate, high net-worth individuals and private equity clients, who have chosen Mauritius as their investment base.

This is primarily done through Adansonia Management Services Limited, their Mauritian licenced offshore Management company and Corporate Trustee, which has channelled investment into no fewer than 16 African countries. In addition to servicing clients and facilitating investment into Africa, Adansonia PE Opportunities Limited, the Groups permanent capital vehicle is an active co-investor with an African focus.

Time: 14h30 - 15h00


International tax principles from a South African perspective, such as substance over form, residency (including place of effective management) and controlled foreign company (CFC) rules. Transfer pricing, focusing on loans to offshore group entities, and practical and tax challenges. BEPS and its impact on international tax treaties with specific reference to permanent establishments.

Roxanna Nyiri, Head of Transfer Pricing at BDO

Roxanna has extensive transfer pricing experience, both in a consulting and auditing role, consulting to large multinational enterprises on all aspects of transfer pricing. Roxanna is also extensively involved in assisting companies with group structuring and implementation for investment into Africa.

She has been on both sides of the market fence being a transfer pricing specialist for the ‘Big Four' in South Africa, the US and Canada, and in various financial positions in diverse industries. She was instrumental in establishing a transfer pricing unit at SARS and has received formal training from the IRS in the USA, IR in the UK and the ATO in Australia.



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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