International investment and trading is something that all taxpayers are familiar with – however when it comes to the tax treatment thereof, it is the complete opposite, where most taxpayers are unsure about what SARS requires.
For this reason, ProBeta offers a session aimed at dealing with this tax treatment in the context of Controlled Foreign Companies and Headquarter Companies.
This session is set up to address the application of the relevant taxation laws, including but not limited to:
• Determining whether a company is a CFC or Headquarter Company, and the impact of ceasing to be such
• The tax treatment of the income of CFCs and Headquarter Companies (including considerations for transfer pricing and CGT, as well as the ring-fencing of certain items)
• Administrative provisions for the tax submissions of CFCs and Headquarter Companies
