Overview

A controlled foreign company (CFC) is a foreign company in which South African residents directly or indirectly hold more than 50% of the participation rights or more than 50% of the voting rights in that foreign company.

Certain anti-avoidance rules were introduced into our legislation to prevent taxpayers from shifting their capital to low tax jurisdictions.

Our session aims to provide you with a practical overview of the South African CFC taxation regime. You will be able to identify a controlled foreign company and understand the potential tax impact.  The session will also cover the application of primary exemptions to controlled foreign company taxation and recent case law developments on the topic.

Webinar content

• What is a CFC?
• What are the implications of being a CFC?
• Understand what is CFC “net income”
• The primary exemptions
  • “High-tax” exemption
  • FBE exemption
• Coronation judgement and impact on FBE exemption
• CFC “exit taxes”

Competencies developed in this webinar

• You will be able to identify a CFC.
• Apply CFC exemptions.
• Understand CFC “exit taxation".

Presenter

Cor Kraamwinkel

Cor is an international tax specialist with more than 13 years' experience. He has experience in the application and interpretation of tax treaties, holding company regimes, withholding taxes, permanent establishments, international tax structuring for both inbound and out-bound clients, exchange control regulatory matters and South African corporate tax. He has worked with clients across numerous industries and sectors, including agriculture, finance and banking, manufacturing, mining, entertainment, ecommerce, retail, insurance, energy, and private equity houses. He was named by Best Lawyers 2021 as a leading individual.

Qualifications

HDip (International Tax), University of Johannesburg, 2008.

LLM (Tax), University of South Africa, 2006.

LLB, University of South Africa, 2004.

BCom (Marketing), University of Pretoria, 1998.

Admitted attorney of the High Court of South Africa.

CPD

Attending this webinar and the successful completion of the online assessment will secure a certificate of completion for 1 hours of Tax CPD.

Event Investment

Free for Tax Practitioner, Tax Accountant CPD subscribers and Practice Packages. Not a CPD subscriber yet? Click here to register now.

Regular price: R495.00

SAIT member special rate: R395.00

Group booking discounts available when you register for a group.

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 be received 2 days after the event, legal action will be taken
• Proof of payment will be requested at registration, if payment does not reflect on Tax Faculty's bank account.
• Cancellations:
  • Only written notice of cancellation will be recognized.
  • 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.
• Tax Faculty`s liability in the case of an event being cancelled will be limited to a refund or credit of the event fee.
• Please click here for the full terms and conditions.