11th Annual Tax Indaba and 13th Annual Transfer Pricing Summit
The 11th Annual Tax Indaba and the 13th Annual Transfer Pricing Summit, produced by the South African Institute for Taxation (SAIT), bring together leading experts in taxation and transfer pricing to discuss critical developments and emerging trends in South Africa and across the African continent. These events provided an invaluable platform for professionals to share knowledge, debate policy, and explore the future of tax compliance, dispute resolution, and transfer pricing frameworks.
We particularly focus on the sessions led by key members of our professional team and/ or co-lecturers on our postgraduate programmes through Middlesex University, London – Roxanna Nyiri, Schalk Pieterse, Karl Muller, Okkie Kellerman and myself.
CLICK HERE TO REGISTER FOR THE 11th ANNUAL TAX INDABA
CLICK HERE TO REGISTER FOR THE 13th ANNUAL TRANSFER PRICING SUMMIT
Overview of the 11th Annual Tax Indaba
The events will be held back-to-back, from September 9th to 12th, 2024, at the Southern Sun Cape Sun in Cape Town.
Key Discussions at the Tax Indaba
- Economic Outlook 2024
- Focus: Inflation, interest rates, and the trajectory of the South African Rand.
- Speakers: Konstantin Makrelov (South African Reserve Bank) and Phumlani Majozi (Economist).
- Tax Fraud and Evasion
- Focus: Notable cases of tax fraud, whistleblower roles, and combat strategies.
- Chair: Mogola Makola.
- Panelists: Johan van Loggerenberg (Bowmans) and Wayne Duvenhage (OUTA).
- The Evolution of the South African Tax System
- Sessions: Explored the past 30 years of tax reforms and what future changes may look like.
- Speakers: Michael Katz (ENS), Trevor Manuel (Old Mutual), and Judge Dennis Davis (SAIT).
- The Future of Incentives in a Post-OECD World
- Focus: The impact of OECD’s Pillar II and other global tax initiatives on South Africa’s tax incentives.
- Speakers: Karl Muller (Unilever) and Pascal Saint-Amans (Former Director of OECD’s Centre for Tax Policy and Administration).
- Transfer Pricing: From Being Nowhere to Everywhere
- Focus: The rapid growth of transfer pricing regulations and their impact on compliance.
- Speakers: Roxanna Nyiri (Transfer Pricing Solutions), Phillip Fouche (KPMG), and Jens Brodbeck (Deloitte).
- The Courts – Which Way Are They Leaning?
- Focus: The evolving role of courts in shaping tax law, particularly in areas like transfer pricing.
- Speakers: Schalk Pieterse (TRM Law), Ntebaleng Sekabate (ENS), and Emil Brincker (CDH Legal).
Key Sessions of the 13th Annual Transfer Pricing Summit
Highlighted Discussions at the Transfer Pricing Summit
- Opening Address: Transfer Pricing Developments in Dispute Resolution
- Speaker: Dr. Daniel N Erasmus.
- Focus: The evolution of dispute resolution in transfer pricing, including recent developments and key challenges facing South African entities.
- ABD Limited v Commissioner
- Focus: South Africa’s first real transfer pricing case, with a surprising focus on intellectual property.
- Speakers: Dr. Daniel N Erasmus (Tax Risk Management) and Okkie Kellerman.
- The Latest OECD Statements on ‘Amount B’
- Focus: The implications of the OECD’s final version of ‘Amount B’ on baseline marketing and distribution activities.
- Speakers: Christian Wiesener (KPMG), Marcus Stelloh (BDO), and Archi Ramana (PwC).
- Regional African Transfer Pricing Trends
- Focus: Emerging trends in African transfer pricing enforcement and compliance.
- Speakers: Billy Joubert (Deloitte), Cabrini McCarrick (Regan van Rooy), and Patrick McLennan (BDO).
- Global Highlights in Intra-Group Financing
- Focus: The latest developments in intra-group financing, including key global cases.
- Speakers: Steven Breslin (Deloitte), Michael Butler (PwC), and Henry Mundeya (Taxation Helpdesk).
- Transfer Pricing in Low Tax Jurisdictions
- Focus: The rising risks and challenges faced by entities operating in low-tax jurisdictions.
- Speakers: Fazeel Soyfoo (Andersen), Liam Purcell (Aurifer), and AJ van Niewenhuizen (vanbain).
Special Focus: The Role of Transfer Pricing in South African Tax Law
The discussions at the Tax Indaba and Transfer Pricing Summit underscore the growing importance of transfer pricing within South Africa’s tax framework. The spotlight on transfer pricing reflects its evolution from a peripheral issue to a central concern for tax authorities and multinational corporations operating in the region.
Emerging Themes and Takeaways
- Integration of Pillar II: Both events highlighted the increasing influence of OECD’s Pillar II on global and local tax practices, signalling a shift towards more robust and comprehensive tax systems.
- Focus on Dispute Resolution: The importance of dispute resolution mechanisms in transfer pricing was emphasized, particularly in light of South Africa’s first significant transfer pricing case.
- Enforcement and Compliance: Across Africa, there is a clear trend towards stricter enforcement of transfer pricing regulations, with increased scrutiny from tax authorities.
- The Role of Technology: Advances in technology, particularly in areas like VAT and data management, are shaping the future of tax compliance.
IN CLOSING
Our team will have a meet-and-greet desk at both events. We warmly invite you to contact us at office@taxriskmanagement.com to schedule a time to meet with any of our team members or speakers.
If you are unable to attend the event, be sure to check back here for updates on the key highlights from the conference. We will also be recording my opening session and the discussion on ABD vs SARS, which will be made available to all our followers on this platform.