1. Click to edit Master subtitle style
Doing business in Angola South African considerations*
*connectedthinking
PwC
Click to edit Master subtitle style

2. Topics for discussion Methods of doing business Limited presence
Branch of SA company
Incorporated subsidiary
Funding alternatives
Equity
Loans
Withholding tax planning
Other considerations
Exchange control
Employees / individuals
Value Added Tax
Custom duties
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3. Limited presence Scenarios Trading with customers / clients in Angola
Methods of doing business
Limited presence
Scenarios
Trading with customers / clients in Angola
No formal presence
Temporary employee
Agency contract
Commercial concession contract
SA world-wide basis of taxation
Foreign tax credits
Exchange control
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4. Branch of SA company World-wide basis of taxation
Methods of doing business
Branch of SA company
World-wide basis of taxation
Set off of foreign profits against local losses
Head office cost allocation
Transfer pricing
Exchange control
Foreign tax credits
SA sourced income
Angola tax rate 35%
No WHT on profit repatration
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5. South African subsidiary
Methods of doing business
South African subsidiary
SA resident?
Effective management
Register as SA taxpayer
SA tax on world-wide income
Controlled foreign company
>50% of participation rights held by SA residents
Business establishment
Diversionary transactions
Passive income
Intra-group passive income
IT10 form
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6. South African subsidiary (continued)
Methods of doing business
South African subsidiary (continued)
Exchange control
Transfer pricing
Profit repatriation
Management fees & interest
Foreign tax credits
Foreign dividends
>25% equity shareholding
10% withholding tax
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7. Funding alternatives Equity funding Loan funding SARB approval
Residence based tax / CFC legislation
Transfer pricing
Interest on borrowed funds
Exchange differences
Taxation of foreign dividends
Deductible expenses
Foreign tax credits
Taxation of interest
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8. Withholding tax planning
Payments subject to withholding tax
Dividends 10%
Interest 15%
Royalties (also equipment rental) 10%
Management / service fees
No double tax treaties
Splitting of goods and services (local & foreign)
Domestic SA tax credits
Source of income
Proof of payment
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9. Exchange control All foreign exchange transactions
Other considerations
Exchange control
All foreign exchange transactions
- Authorised dealers
- Timing of cash payments
Foreign investment
- SARB approval
- Investment limits
Repatration of foreign dividends
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10. Employees / individuals
Other considerations
Employees / individuals
Residence
Ordinarily resident
Dual resident
Relief for double taxation
Section 6quat
Section 10(1)(o)
CGT exit charge
SA employees’ tax
Temporary absence
Branch of SA company
Subsidiary of SA company
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11. Indirect taxes: Value Added Tax
Other considerations
Indirect taxes: Value Added Tax
Export of goods
Direct exports
Indirect exports
Services
Rendered in SA
Rendered in Angola
Presence of recipient in SA
Documentation requirements
Branch of SA company
Subsidiary of SA company
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12. Custom duties Export documentation Export value Export tariffs
Other considerations
Custom duties
Export documentation
Export value
Export tariffs
Border crossings
Moving goods in transit
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13. Comprehensive research & planning Local & foreign perspective
Conclusion
Comprehensive research & planning
Local & foreign perspective
Obtain professional advice
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14. Questions
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