Armagh Financial Services

International Tax Advisory

Determination of Jurisdiction to Tax

Facilitation of Tax-Emigration and obtaining Non-Resident Tax Status

  • Source and Residence Tax Rules
  • Taxation of Individuals, Treaty Provisions affecting individuals. All aspects of Tax Emigration.
  • Taxation of Companies, Resident and Non-Resident, Corporate Restructuring Rules, Dividends under Tax Treaties.
  • Trusts, RSA tax consequences, beneficiaries and their rights, International issues surrounding Trusts.
  • Taxation of Partnerships.

Analysis of Double Tax Agreements

  • Analysis and interpretation of Double Tax Agreements in respect of their impact on Individuals, Trusts, Corporate Entities and Partnerships.
  • Advice on the implications of setting up corporate entities in multiple jurisdictions.

An analysis of business profits attribution to permanent establishments in a jurisdiction

  • Examination of a Foreign Jurisdiction’s right to tax the profits of a non-resident corporate entity in terms of that foreign jurisdictions legal system and the applicable Double Tax Treaty if such a Treaty exists.

Advice on Cross-Border Financing

  • The use and implications of various instruments involved in Cross-Border Financing e.g. Debt vs Equity, Hybrid Instruments, Derivatives and Cross-Border Leasing.
  • The implications of proposed regulations by the OECD to curb BEPS (Base Erosion and Profit Shifting).

An Analysis of Withholding Taxes

  • Analysis of Withholding taxes applied by a tax jurisdiction.
  • Specifically insomuch as the withholding taxes levied relate to interest and dividends.

The Use of Tax Havens

  • Analysis of the use of Tax Havens in respect of the corporate entity.
  • The do’s and don’ts of setting up an entity in a Tax Haven.

Other

  • Tax avoidance, advice on how to reduce the risk of the Tax Authorities deeming tax avoidance to have taken place.
  • Use of Controlled Foreign Corporations to deem income accruing to an Off-Shore entity to have accrued to a South African Resident, ( what you need to do to ensure that this does not happen).
  • Enforcement and Collection of International Tax obligations, (to what extent can SARS can collect tax due by you in another jurisdiction.
  • Advice on how to approach an audit of your entity located in another jurisdiction.

Cost

  • R3250 per hour (excl. VAT), a quote will be provided prior to any engagement.