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Australia-Africa Services Group

Tax 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.

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