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UnscheduledTax Planning in Africa – Selected Critical Issues

Important Notification - 12 March 2020

After careful consideration, IBFD has decided to postpone the 6th Africa Tax Symposium. and the Masterclas: Internation Tax Planing in Africa - Selected Critical Issues.

With the World Health Organisation’s declaration that the COVID-19 virus is now a pandemic, combined with the fact that many countries worldwide are closing borders, placing travellers in quarantine, and restricting travel, we feel that the risk to conference delegates is too great in the current health climate. For this reason, we are postponing the symposium to a later date.

Once a new date has been confirmed, we will update this page accordingly.

Thank you for your ongoing support of the Symposium. We look forward to reuniting with you soon.

If you would like to be informed once the new date is confirmed, please contact

As a prelude to the 6th IBFD Africa Tax Symposium, we are delighted to present the third edition of our international tax and transfer pricing-focused Masterclass on African taxation providing a unique learning platform for African tax practitioners. This two-day advanced-level course will provide participants with a platform to be able to learn, share and debate the most pressing issues in international taxation and transfer pricing including permanent establishment and transfer pricing cases, capital gains taxation of immovable property and natural resources, withholding tax planning and substance considerations.

Mount Meru Hotel, Arusha - The 6th IBFD Africa Tax Symposium will take place at the same location from 20 to 22 May.
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
Arusha - Tanzania
Course code:
Client offer:
20% discount for Global Tax Premier 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).
Tax Planning in Africa – Selected Critical Issues
Overview and learning objectives

This two-day advanced-level course aims to provide African tax professionals with practical and comprehensive coverage of the most important issues in international taxation and transfer pricing. A brief outline of the objectives per day are set out below:

Day 1: Monday, 18 May

  • Practical impact of the latest tax policy, legislative and case law developments on the international stage (including at the OECD, UN and selected jurisdictions notably the US). 
  • Latest trends in tax treaty policy in Africa and the likely impact of tax treaty anti-avoidance rules that are being incorporated in tax treaties in the region. 
  • Taxation of capital gains under tax treaties with a special focus on immovable properties and offshore structures used in tax planning in respect of capital gains taxes on the sale of assets in Africa.
  • The permanent establishment concept and the most recent international cases on the topic

Day 2: Tuesday, 19 May

  • Profit repatriation and structures put in place for the avoidance of withholding taxes in cross-border situations. Participants will learn the impact of tax treaties and the common interpretation issues arising from treaty application.
  • Substance considerations concerning domestic provisions and the recommendations under the OECD Base Erosion and Profit Shifting (BEPS) package, including Minimum Standards
  • Recent transfer pricing cases that are of relevance to Africa. Participants will learn the arguments put forward by taxpayers, tax administrations and courts from different jurisdictions to solve complex transfer pricing issues that practitioners may face in Africa.
  • African developments to tie in some regional and domestic regulatory changes with the 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 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
  • Trends in Tax Treaty Policy in Africa: Impact of Treaty Anti-Avoidance Rules
  • Taxation of Capital Gains and Offshore Indirect Asset Transfers: What is the Current State of Play?  
  • Current Court Cases on Permanent Establishments from Around the Globe: Lessons for Africa 
  • Withholding Tax Planning: Effective Repatriation of Income out of Africa
  • Substance Considerations and Anti-abuse Measures: Getting it Right 
  • Recent Transfer Pricing Cases from around the Globe: Lessons for Africa 
  • African Tax Highlights – Some Attention Points for Cross-Border Business Activities in Africa 
  • Emily Muyaa is the Managing Principal for Sub-Saharan Africa region within the IBFD Knowledge Centre. In this capacity, she oversees IBFD‘s product offering in the region. Ms Muyaa regularly...
  • Ridha Hamzaoui is the Managing Principal for the Middle East and North Africa region within the IBFD Knowledge Centre. Mr Hamzaoui has an LLM in International Tax Law from the International Tax...
    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...