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27 - 28 May 2019Managing Risks and Harnessing Opportunities in International Taxation and Transfer Pricing in Africa

As a prelude to the 5th IBFD Africa Tax Symposium, we are delighted to present the second edition of its international tax and transfer pricing-focused Masterclass providing a unique learning platform for African tax practitioners. After the full-house first edition in Mombasa, the ATS will again be preceded by this two-day upper intermediate/advanced-level course in which participants will be able to learn, share and debate the most pressing issues in international taxation and transfer pricing including global developments, cross-border employment income, digital economy, services and finance.
From 29 to 31 May, the 5th IBFD Africa Tax Symposium will take place at the same location.
Tax Courses
Stellenbosch - South Africa
Course code:
EUR 1,200 / USD 1,440 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
Early Bird Discount: a 30% discount will be automatically applied for registrations received 60 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
Managing Risks and Harnessing Opportunities in International Taxation and Transfer Pricing in Africa
Overview and learning objectives

This two-day upper-intermediate/advanced-level course aims to provide African tax professionals with a practical and comprehensive coverage of the most important issues in international taxation and transfer pricing. 

After a brief introduction to the latest policy, legislative and case law developments on the international stage (OECD BEPS, Multilateral Instrument (MLI), OECD and UN Model Tax Conventions, US, Chinese and EU tax reforms) participants will have the opportunity to discuss with instructors and peers the relevance and practical impact of these developments on foreign investments and on their daily work in Africa. The second session on Day 1 concentrates on the current debate on anti-tax avoidance measures in the post-BEPS era. Riding the global waves, African policymakers show legislative activism in introducing complex general and targeted domestic law measures, tax administrations often interpret and apply them in an unorthodox way, and courts often sanction their application without proper attention to the core business perspective of multinational enterprises. That is why the instructors will provide an analytical framework for approaching these new measures that will help tax practitioners prevent potential controversies. Finally, after a session on permanent establishments, the first day will be closed with a lecture dedicated to e-commerce and the digital economy. African businesses, start-ups and other entrepreneurs are pioneering in the application of e-commerce business models as well as digital tools, which necessitates a thorough examination by tax practitioners. Questions related to income classification, permanent establishment issues, tax treaty application, and direct and indirect tax solutions will be looked at. The African domestic law solutions will be contrasted with global developments in this realm so that participants will be able to rely on the already available foreign experience in managing compliance with regulatory challenges.

On the second day, the course will continue with a presentation on services. Cross-border services constitute a major revenue stream for African businesses but equally challenge tax administrations and taxpayers from several different perspectives. Issues to be covered include transfer pricing (e.g. proof of delivery, benefit test, calculation methods, and classification of chargeable and non-chargeable services), permanent establishments, withholding tax and other tax treaty-related problems. Recent developments at the OECD (including the latest OECD transfer pricing-focused scoping document) and African domestic regulations will be equally looked at by the instructors. The second session on Day 2 will assist course participants in setting up and maintaining robust financing structures. The nitty-gritty of holding, treasury and other financial transactions and cross-border structures will be discussed from a tax and transfer pricing point of view to give a short overview for practitioners of the dos and don’ts in this field. The latest OECD discussion draft on the transfer pricing aspects of intra-group finance will be briefly examined too, before the instructors will contemplate the implications on finance stemming from the OECD MLI.

The penultimate session has a case law focus. The instructors will discuss the leading global international tax and transfer pricing cases to examine the strategic narrative taxpayers (or tax administrations) should present to win such cases. Participants will learn the arguments put forward by taxpayers, tax administrations and courts from different jurisdictions to solve complex tax issues that practitioners face on a daily basis in Africa. The course ends with a presentation on African developments to tie in some regional and domestic regulatory changes with the already discussed global international tax and transfer pricing trends.

Field of study


Who should participate

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

Interactive course - "Group Live"

To safeguard the interactive nature of the course, including group discussions, a maximum of 50 participants will be accepted. Early registration is therefore recommended.

Continuing Professional Education
Recommended CPE points for this course: 12.5 (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.

  • Current issues in international taxation and transfer pricing from around the globe – impact on African inbound and outbound investments
  • The new age of anti-tax avoidance measures: how to obtain clarity in chaos?
  • Managing permanent establishment risks under tax treaties and domestic law in Africa
  • Taxation of e-commerce and the digitalized economy – the global and African perspective 
  • Addressing the tax and transfer pricing risks of cross-border (intra-group) services 
  • Setting-up and managing sustainable (intra-group) financing structures 
  • Recent international tax and transfer pricing cases from around the globe: practical insights for African tax and transfer pricing experts 
  • African tax highlights – some attention points for cross-border business activities in Africa
  • Emily Muyaa
    Emily Muyaa is the Managing Principal for Sub-Saharan Africa in the IBFD Africa and Middle East Department. In this capacity, she oversees IBFD's product offering in the region. Ms. Muyaa...
  • Clive Jie-A-Joen
    Clive Jie-A-Joen works in the Financial Markets practice group of Simmons & Simmons LLP. His practice focuses on analysing, designing, planning, organizing, documenting and defending the...
  • Julia de Jong is a manager in the Government Consultancy Department of IBFD with a multi-disciplinary professional background. Since early 2017, her main focus is on the impact of emerging...
    Michael Honiball is a director at Werksmans Attorneys and heads the firm’s International Tax Practice. With extensive international and corporate tax advisory experience, Mr Honiball...
    Johann Hattingh is Associate Professor in the Law Faculty of the University of Cape Town, South Africa.  He is an Advocate of the High Court of South Africa formerly practiced in the field of...