International Tax

Tuffias Sandberg strives to simplify the challenges businesses face.

Due to the ever-changing legislation around international taxation with regards to cross border financial transactions, it is imperative that your business stays compliant. 

Understanding the effect of these developments on business operations and transactions between countries is vital.

To enhance our service offering we have partnered with Roxanna Nyiri. 

Roxanna’s boutique transfer pricing and international tax consulting firm works directly with your team applying expertise and experience in transfer pricing and other international tax matters to provide, prepare, document and assist in defending international transactions. 

We are able to provide advice on:

  • Cross border investments and transactions
  • Residency, permanent establishments and Controlled Foreign Companies
  • Transfer pricing and thin capitalisation
  • Double taxation agreements and foreign tax credits
  • International Tax Structuring
  • Due Diligences
  • Court Cases – Expert Witness
  • All other matters relating to international transactions






Click here for Roxanna’s bio.

Transfer Pricing

Transfer pricing is a significant tax issue for multinationals trans-acting cross-border with related parties.

Transfer pricing generally relates to all intercompany transactions.

In South Africa, the transfer pricing legislation applies to all cross-border, intercompany transactions between connected parties where there is at least a 20% shareholding.

It would need to be supported by Revenue Authorities across the globe that pricing is market-related.

The recent implementation of Country by Country reporting creates greater transparency to tax authorities across the world on the activities, size, financial and tax position of companies within the Multinational Entity Group.

Our International Tax Services provides advice on strategic transfer pricing in the optimisation of transaction and money flows relating to your Multinational Group. 

We conduct risk reviews to identify transfer pricing risk, compliance in the form of transfer pricing policies and documentation and planning reports.

We also compile country by country reports which include industry, benchmarking, economic and financial analyses and assistance with the implementation of transfer pricing policies.

Our services relating to cross-border transactions include:

  • Supply Chain Planning using Transfer Pricing as a planning tool
  • Formulation of Transfer Pricing Policies and Intercompany Agreements
  • Transfer Pricing Documentation, Master and
  • Local Files (covering all jurisdictions)
  • Transfer Pricing Benchmarking Memoranda
  • Transfer Pricing Audits and Dispute Resolution
  • Transfer Pricing Risk Reviews


If you would like to know more about International Tax or Transfer Pricing, contact us for assistance.