Tracking international operations and legislation over 40 years
Our client, a South African resident, was concerned that his multi-million business could be exposed to significant tax, interest and penalties.
His historical holding and trading structure had been established 40 years previously when he had relocated from Western Europe but no filing position had been adopted in South Africa.
- We undertook a detailed review of each transaction that led to the formation of the holding and operating structure.
- Then we tracked the company’s expansion alongside legislative changes in South African tax law and offshore trust reporting over a 40 year period.
- We concluded that our client had a South African reporting obligation but that the potential latent tax liabilities could be successfully mitigated.
- We proposed restructuring the top holding entity to make the ownership (and control) structure clear, removed a latent estate liability through the use of a non-South African hybrid entity/quasi-trust and restructured the existing financing arrangements.