South Africa

International Tax 

Multinationals require global tax planning to ensure an optimal group tax rate is achieved. This is an effective and efficient way companies can improve their bottom line. Tax is one of the most important variables as it assists in the determination of the optimal  corporate structure, where intellectual property should be located and how global supply chains should be configured to help contain overall effective tax rates.

Robyn Berger

Robyn Berger

Director, International Tax

Tel: +27 (0)83 273 7390

KPMG’s International Tax team in South Africa has extensive experience in assisting multinationals with effective global tax planning and the efficient implementation of international tax and transfer pricing legislation.


How can KPMG’s International Tax practice help you?


KPMG’s International Tax team in South Africa is able to advise on various issues including:


International Tax:


  • establishing tax-compliant and business-efficient inbound and outbound solutions for multinationals 
  •  tax planning solutions for multinationals, including advising on global tax charges in a way that can achieve an enhanced global tax rate within the constraints of cross-border tax legislation and treasury requirements
  • the efficient repatriation of income to South Africa from foreign sources and the use of any rebate due in respect of foreign taxes on that income
  • managing secondary tax on companies (“STC”) liability, arising from dividends repatriated to foreign investors
  • interpretation of double taxation agreements and the correct application thereof
  • assisting with the compilation and submission of certain documents to relevant authorities, for example applications for exemption in terms of double-taxation agreements, including royalty exemption certificates
  • assisting with compiling and submitting the relevant documents to the south African Revenue Service (SARS) for an Advanced Tax Ruling (“ATR”) in circumstances where the interpretation and application of South African tax legislation is not clear, thus providing certainty as to the correct application of law.


Transfer pricing:


  • guidance on South Africa’s thin capitalisation regulations and assistance with maintaining a debt to equity ratio within safe harbour limits
  • planning and conducting transfer pricing compliance reviews, where the team has access to relevant KPMG and other software and databases
  • assistance with completing and submitting applications to SARS for relaxation of the allowable thin capitalisation debt to equity ratio.


Exchange Control:


  • the South African exchange control implications of various transactions for South African and foreign residents, for inbound and outbound investments
  • assistance with drafting exchange control applications for approval of inbound and outbound investments, where necessary.