Overview

Cross-border transactions are no longer the exclusive domain of large multinationals. South African businesses are increasingly dealing with foreign suppliers and customers, offshore investments, foreign funding, and international expansion. These transactions bring real commercial opportunity, but they also carry tax risks that are easy to overlook and costly to correct after the fact.

This CPD event unpacks the key South African tax principles that apply to cross-border dealings, including the taxation of foreign income, foreign exchange gains and losses, transfer pricing, withholding taxes, and the application of double tax agreements. Using practical, worked examples, including a detailed intercompany loan case study, the session moves beyond theory to show practitioners how to identify risk, apply the legislation correctly, and structure transactions with greater confidence.

Webinar Content

• Overview of cross-border transactions in the South African context.
• Taxation of foreign income.
• Foreign exchange gains and losses: accounting treatment vs. tax treatment.
• Section 24I(10A): deferral of foreign exchange gains/losses on group and connected-person loans.
• Interest withholding tax obligations and DTA relief.
• Section 23M: limitation of interest deductions.
• Transfer pricing considerations for cross-border loans and “affected transactions”.
• Worked example: intercompany loan between a foreign holding company and local subsidiary.
• Practical checklist for structuring and reviewing cross-border loan arrangements.

Competencies Development

• Ability to distinguish between accounting and tax treatment of foreign exchange gains/losses on cross-border loans.
• Ability to apply section 24I(10A) to determine when forex gains/losses are deferred.
• Ability to identify withholding tax obligations on cross-border interest payments and apply relevant DTA relief.
• Ability to assess interest deduction limitations under section 23M.
• Ability to identify transfer pricing risk in cross-border intercompany loans.
• Ability to apply a practical checklist when structuring or reviewing cross-border transactions to avoid unintended tax consequences.

Presenter

Fathima Dawood

Fathima Dawood CA(SA) is an independent tax consultant with over 15 years of experience spanning tax consulting, corporate in-house taxation, and academia. Her career includes senior tax roles at PKF Durban, Bowmans Law and RCL Foods Ltd, including a tenure as a third year Taxation Lecturer at the University of KwaZulu-Natal. She currently serves on SAICA's National Tax Committee and the Eastern Region Tax Committee, and is completing an LLM in Taxation, having passed the first year cum laude.

CPD

Attending this webinar and the successful completion of the online assessment will secure a certificate of completion for 2 hours of 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:  R460.00
• Group booking discounts available when you register for a group.

Payments and cancellations

• All payments must be made by EFT or by credit card, at least three working days before commencement of an event.
• Kindly note that should payment not be received two days after the event, legal action will be taken.
• Proof of payment will be requested at registration if payment does not reflect in The Tax Faculty’s bank account.
• Only written notice of cancellation will be recognized.
• Conditions:
  • If the cancellation occurs more than four working days prior to the event no cancellation fee will be charged.
  • If the cancellation occurs less than four 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.
• The 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.