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UnscheduledIBFD Masterclass: Selected Issues in International Tax Structuring in Africa – Day 1

For participants who wish to register for only Day 1 (Monday 7 May 2018) of the 2-Day IBFD Masterclass: Selected Issues in International Tax Structuring in Africa, to be held on 7-8 May 2018 in Mombasa, Kenya.
On 9-11 May the 4th IBFD Africa Tax Symposium will take place.
Please note: This course is not currently scheduled. The price, program and instructors are detailed as per the previous course for information purposes only and may be subject to change.
Tax Courses
Mombasa - Kenya
Course code:
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
Early Bird Discount extended: a 30% discount will be automatically applied for registrations received before 15 March 2018 (cannot be used in conjunction with other discounts).
IBFD Masterclass: Selected Issues in International Tax Structuring in Africa – Day 1

Overview and learning objectives

This two-day upper-intermediate/advanced-level course concentrates on a number of common international tax structuring scenarios involving African businesses. It examines the widely used regional tax planning routes, structures and tax treaties. Attention will also be paid to domestic and regional tax policy and transfer pricing developments, such as base erosion and profit shifting (BEPS) and the implementation of the Multilateral Instrument in Africa.

The first day concentrates on the issue of permanent establishments. It provides an in-depth analysis of the core elements of the concept and shows their importance for businesses in Africa. Practical issues, such as the allocation of profits in light of the new OECD BEPS substance requirements and permanent establishment risks surrounding sales and marketing service providers, toll and contract manufacturing entities, inventory management and warehousing as well as construction businesses will be examined. The implementation and impact of OECD BEPS Action 7 (Prevent the Artificial Avoidance of Permanent Establishment Status) will be analysed and discussed.

(On the second day, course participants will discuss and learn about transfer pricing developments (material and compliance) affecting African business and operating models as well as legislative changes in some major jurisdictions (e.g. the Netherlands, Mauritius, Luxembourg and Switzerland) that are commonly used as investment gateways to Africa. The course will present the latest transfer pricing issues for multinational enterprises with African manufacturing and distributor entities as well as the controversies and impact of the OECD BEPS Project including those regarding intangibles, services and trade of commodities. The second day also covers some common tax planning tools involving holdings, financing and treasury companies and branches. The final session provides African tax practitioners with a sound understanding of global tax developments (such as US tax reform and EU developments) and their impact on local businesses.)

Field of study


Who should attend?

The course is suitable for professionals, such as tax managers and directors, practitioners in tax advisory firms, other in-house tax and accounting specialists in commerce and industry, and government officials, who deal with international tax structuring in the region and wish to gain a deeper technical understanding of relevant tax treaty and transfer pricing developments.

Course level and prerequisites

This is an upper-intermediate/advanced-level course. Participants taking this course will be expected to have a good understanding of at least one national tax system, transfer pricing and the fundamentals of double tax treaties.

Pre-course preparation

In order to participate in this particular course, no advance preparation is necessary. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks.

Interactive course - "Group Live"

To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 50 participants will be accepted. Early registration is therefore recommended.
We invite you to send us in advance any technical, content-related questions you may have. During the course we will try to address your specific questions, but please note that this will depend on the amount of time available, the relevance of the questions and the order in which the questions are received.
Should you have a question, please send it to
Disclaimer: The information provided during the course has been prepared solely for the instruction of course participants. This information is not intended to constitute advice on any particular matter.

Continuing Professional Education

Recommended NASBA CPE points for Day 1 of this course: 6 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for IBFD International Tax Courses.

Course fee and registration details

The course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.
Day 1
  • The role of the permanent establishment concept in international tax structuring
  • The impact of the OECD BEPS Project on the permanent establishment concept
  • Substance considerations and attribution of profits to permanent establishments
  • Case study
Day 2
  • The changing world of transfer pricing in 2018 – the impact of post-BEPS transfer pricing on international structures and business models
  • Common investment routes to Africa – post BEPS
  • Global tax developments and their importance for Africa



  • Ridha Hamzaoui is the Regional Tax Manager for Africa and Middle East regions under the IBFD Africa, Middle East and Latin America Knowledge Group. He is an expert on tax law and tax treaties for...
    Tamás Kulcsár is the Manager of International Tax Training (ITT) at IBFD specialized in EU and international tax law. He is also a contracted expert of the International Monetary...
  • Fred Omondi
    Fred Omondi is East Africa Cross-Border expert at Deloitte. He has over 12 years’ experience in various aspects of taxation including tax reviews and tax health checks, tax audits, transfer...
  • Doris Gichuru
    Doris Gichuru is a manager in Deloitte East Africa and has an extensive experience in transfer pricing. She has assisted multinationals in various African countries (including Kenya, Uganda,...