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.

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


Navigating the African tax landscape


  • The African tax landscape is complex requiring experienced teams in country to help navigate the uncertainty. KPMG’s network of African practices allows us to provide our clients with the latest information on how best to structure African investment opportunities, taking into account both the tax and exchange control laws.
  • We implement solutions that optimise funding structures by minimising tax leakage, while ensuring compliance with local laws.
  • We assist clients to implement tax efficient structures that are simple to maintain and robust enough to withstand scrutiny from revenue authorities.
  • We work to ensure that tax costs are minimised where possible and tax leakage is able to be claimed as foreign tax credits.
  • We also offer a one stop solution through our Africa centre of excellence, that will co-ordinate your interaction with our African offices thereby offering you a single point of contact for all of Africa.
  • A key element to navigating Africa is in managing withholding tax (“WHT”) costs and maximising the ability to claim foreign tax credits.
  • We also advise on potential Permanent Establishment (“PE”) exposure, providing a tailor-made place of effective management (“POEM”) framework and drafting authority levels to manage PE and POEM exposure.


South African international tax


  • 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
  • Advising WHT arising from dividends repatriated to foreign investors
  • Advising the South African income tax consequences for a non-resident on the receipt of interest income and service fees from South Africa before and after the effective date of the imposition of interest WHT and WHT on service fees, respectively, in South Africa
  • 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  on an arm’s length basis
  • Planning and conducting transfer pricing compliance reviews, where the team has access to relevant KPMG and other software and databases
  • Perform transfer pricing studies (including data collection and functional analysis, company and industry analysis and preparation of the economic analysis).


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.


    Robyn Berger

    Robyn Berger


    Tel: +27 (0)83 273 7390