Stream 1: International - Cross-Border Corporate Investment
08:30 to 09:45
Multilateral Treaty Instrument and the Future of Tax Treaties (Panel Discussion)
The multilateral instrument (signed on 7 June 2017) is arguably the most significant event in terms of tax treaties since their early creation in the 1920s. For discussion is the question of the instrument’s impact and the future trend of tax treaties.
Dr Dumisani Jantjies
Parliamentary Budget Office
Prof. Deborah Tickle
09:45 to 10:30
Small and Medium Businesses: Engine for Growth Versus the Tax Gap (Panel Discussion)
Small businesses are a vexing problem for government policymakers. On the one hand, small businesses are said to be the best engine for economic growth in terms of employment. On the other hand, small businesses pose the greatest challenge for the revenue authorities in terms of the tax gap. At issue is how to bridge this divide.
The new country-by-country reporting has been implemented for the first time and will create a sea change in international compliance. The initial challenges and questions arising will be discussed.
11:45 to 12:30
Operating in Offshore Low-Tax Jurisdictions: Continued Viability (Panel Discussion)
Much has been said about the global crackdown on offshore tax avoidance / evasion of multinational enterprises. This session will cover the heightened risks of this new environment as well as remaining options for manoeuvre.
Citibank & Davis Tax Committee
12:30 to 13:30
13:30 to 14:00
The Tax and Exchange Control Implications of Shifting Intellectual Property Offshore (Solo Speaker)
The Reserve Bank has recently announced relaxation of exchange controls in terms of intellectual property. This session will cover the significance of this change in terms of exchange control and tax as well as key restrictions remaining.
Deloitte South Africa
14:00 to 14:30
Tightening of the CFC Regime and Competitive Pressures (Mini-Panel Discussion)
Treasury has shown a propensity to tighten its tax grip on controlled foreign companies since the OECD announcement of BEPS. This session covers the practical impact of these changes, including the recent changes that tighten the diversionary rules.
Prof. Osman Mollagee
14:30 to 15:00
South African Debt Payments to Foreigners: Thin Cap and Other Limitations (Solo Speaker)
One long-standing issue in terms of cross-border payments is the deductibility of cross-border interest. Besides legislative changes, the rules of thin capitalisation have never been resolved since the revised draft interpretation note was issued. This session covers the current state of play.
15:00 to 15:30
15:30 to 16:30
Onus of Proof: What Level of Documents is Sufficient? (Town Hall Discussion)
Taxpayers must have documentation to support deductions, inputs and other claims against tax. The question presented is the level of documentation required to support these claims in terms of reasonableness so as to overcome revenue authority concerns relating to fraud.