Do the South African headquarters provisions provide a competitive alternative for a gateway into Africa for international companies?
Special tax regimes (“STR”) and tax havens are topics that feature in global news on an increasingly frequent basis in particular over the last few years. This can be partially attributed to the global financial crisis that has lead many countries being into financial strife coupled with news reporters and critics commenting on the amount of money that companies are avoiding paying in corporate tax due to the use of tax avoidance schemes and tax havens. Therefore Governments are under increasing pressure to curb the amount of revenues that are lost to other jurisdictions. However, whilst that makes the headlines, there is also a necessity for Governments to incentivise companies into their jurisdiction so to provide further revenue to their economy, in particular for the provision of additional jobs and to assist the property market following the crash, this can therefore be seen as very much a double edged sword. So whilst it is clear that a number of countries, governments and nongovernmental organisations including the Organisation for Economic Cooperation and Development and groups such as the Tax Justice Network are trying to rid the world of tax havens and countries offering special tax regimes, on the other side many Governments are also trying to lure large corporations into their jurisdictions by offering lucrative tax regimes. South Africa is one such country that has decided to incentivise foreign companies in particular those involved in cross border transactions into its jurisdiction by introducing its Headquarter Company Regime.
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