A comparison of the tax efficiency of direct versus indirect investment into South Africa.

Multinational enterprises are continuously in search of investment opportunities to grow their businesses. For over two decades South Africa, being one of the economic powerhouses of Africa, has been one such target for global investors. A company planning to invest in South Africa will attempt to identify the most appropriate way to do so, for tax and non-tax reasons. However, tax consequences are one of the main factors influencing the decision of an investor. While certain companies choose to invest directly into the target country, the majority choose to set up a holding company outside of the investor country. Such a company is known as an intermediary holding company and is defined as a company which is interposed between a shareholder and its foreign subsidiary. The main purpose of this study is to investigate the best manner, for tax purposes, in which a foreign company would invest into South Africa, either directly or indirectly through an intermediary holding company. Should the intermediary holding company option be selected, the company will then need to select the country in which to base its intermediary holding company. Tax havens are commonly used as a base for intermediary holding companies, however, these may not be the most advantageous option in all cases. Literature on intermediary holding companies and tax havens is reviewed and thereafter the study analyses and compares the tax efficiency of a hypothetical UK company investing into South Africa using different options. The options available to the UK Company which are compared, include investing directly into South Africa or investing indirectly through an intermediary holding company based in either Cyprus, Mauritius or the Netherlands, all of which are commonly used as bases for intermediary holding companies. The comparative study on the different intermediary holding company options is performed based on the domestic tax laws of each country as well as the effects of the double tax agreements in force between these countries and other tax jurisdictions. Thereafter, the most tax efficient intermediary holding company option is compared to the tax efficiency of direct investment by the UK Company and a conclusion is reached on which is the best manner for such a company to invest into South Africa, for tax purposes

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