S.Africa: And neighbouring countries discuss beefing up tax enforcement

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SA, neighbouring countries discuss beefing up tax enforcement

Pretoria – The South African Revenue Services (SARS) has convened a forum of commissioners from bordering countries, including Swaziland, Lesotho, Zambia, Botswana, Namibia and South Africa to deliberate on core tax and customs issues.

The forum debated issues linked to illicit financial flows, base erosion and profit sharing, transfer pricing and cross-border enforcement.

According to SARS, the aim was to chart a road map going forward and maximise the respective participating countries’ statutory mandates of revenue collection.

Recently the International Monetary Fund released a working paper, which said “the cost of multi-national companies deliberately avoiding tax exceeds $200 billion per year”.

The Organisation for Economic Capacity and Development (OECD) said developing countries lose three times more to tax havens than what is received in international aid per year.

Added to this, a report by the African Union on illicit financial flows said $60 billion is annually tapped from the continent.

It is against this backdrop of abusive tax practices, SARS convened the forum.

SARS Commissioner Tom Moyane called for collective cross-border strategies to respond to the challenges, which can lead to a continental discussion under the African Tax and Administration Forum (ATAF).

Moyane, in his opening address at the forum, said exports out of developing countries are often under-invoiced so that income is accrued abroad, and imports into developing countries are often under-invoiced, so that the excess payment accumulates in foreign accounts.

He acknowledged the increase in automatic exchange of tax information and posed the question on how this can be leveraged.

The meeting culminated in a joint statement of in-principle agreements and actions. – SAnews.gov.za

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Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
Typical outcomes Build defensible TP files and strategies, improve audit readiness Design cross-border structures within rules, mitigate double tax Apply SA tax law accurately, manage reviews and disputes
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Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
Core focus Case theory, evidence files, expert reports, witness prep, courtroom strategy Operating models, KPIs, workflows, stakeholder management, coaching VAT design, place of supply, input credits, exemptions, WHT interactions Risk identification, controls, documentation, audit readiness, dispute playbooks
Delivery mode Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study
Duration 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time
Outcomes Confident litigation preparation and defence for TP disputes Stronger execution, clear roles, measurable team performance Reduced VAT errors, better cash flow, fewer surprises at audit Structured governance, fewer findings, faster dispute resolution
Prerequisites TP fundamentals recommended Supervisory experience helpful Basic VAT knowledge helpful General tax experience helpful
Pathway Progress to PG Certificate in Transfer Pricing Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) Progress to PG programmes, International Tax or SA Tax Law Progress to PG Certificate in International Taxation or Transfer Pricing
Assessment End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected