Australia-Africa Services GroupTax Advisory and Compliance |
The AASG provides the full suite of services associated with tax advisory and compliance but with a specific
focus on operations in or investment into Africa by Australian entities. These functions may include
International tax planning and structuring advice including:
- Advice on the interaction of African tax regimes with the Australian tax regime
- Negotiation of tax regimes/concessions with African governments
- Minimisation of the impact of Australian CFC legislation
- Minimisation of taxes on cross-border dividend, interest and royalty flows between Africa and Australia
- Tax implications on exiting the African investment
- Use of tax treaty networks in Africa to minimise taxes
- Choice of investment vehicle in the African country
- Design and implementation of optimal holding and operating structures to ensure minimisation of taxes at low risk
- Structuring cross-border share schemes and other forms of executive remuneration and retirement funding in a cross-border context
- Transfer pricing advice
- Capitalisation of African operations and attendant thin capitalisation provisions
- Merger and acquisition advice including the
international tax aspects of due diligence reviews
Global employer services covering advice on employment issues including:
- International assignment services including tax and immigration advice where employees move
between Australia and the African countries - Tax and immigration compliance management
- General human capital advice covering remuneration structuring and other issues
- Available R&D incentives
- Australian projects
- For Australian activities on overseas projects - Exchange control advice in African countries
- Indirect tax planning
- Customs and excise advice
Advice on up-to-the minute tax issues currently arising in African countries or which may arise in the future which could impact the Australian investor. Examples of this include:
- Existing and impending Mining Royalty legislation in various African countries
- Requirement to have a local partner in the African country – such as BEE requirements in Namibia
- Possible future application of transfer pricing principles to inter-company loans into and out of Mauritius
- Namibia recently passed new tax legislation denying the deductibility of provisions for rehabilitation expenditure
- South Africa has replaced its secondary tax on companies (where the company is taxed at 10% on dividends declared) with a 10% dividend witholding tax where the shareholder pays the tax instead of the company
- Burkina Faso is considering offering more tax concessions to foreign mining companies to encourage investment in the mining sector
- Tax compliance.
