Overview 

Legal practitioners face shifting ground as the South African Revenue Service (SARS) intensifies its scrutiny of cross-border transactions and expatriate residency cessations. The activation of automated risk profiling on eFiling, alongside mandatory registrations for the Global Minimum Tax (GMT) under the Global Minimum Tax Act of 2026, means traditional cross-border advice requires immediate reassessment. Missing the critical tax triggers during a corporate restructuring or an estate planning exercise exposes the legal advisor to significant professional indemnity risks.

Understanding the interaction between domestic source rules, Double Tax Agreements (DTAs), and the newly introduced Advance Pricing Agreement (APA) programme is no longer the sole domain of specialized tax firms. Litigators, commercial lawyers, and general practitioners must accurately identify permanent establishment (PE) risks and treaty eligibility to protect corporate clients from double taxation and unexpected SARS audits. This masterclass bridges foundational international tax principles with the complex compliance realities of 2026.

Join Adv. Christel van Wyk on 21 October 2026 from 10h00 to 12h00 for a structured analysis of South Africa's modern international tax framework, designed specifically to safeguard your advisory practice and enhance your corporate client representations.

Learning objectives 

Attending this webinar will equip you with the following skills: 

• Assess the legal status and domestic interpretation of Double Tax Agreements in terms of section 108 of the Income Tax Act 58 of 1962.
• Evaluate residency cessation processes to properly advise clients on exit taxes and the formal cessation of South African tax residency.
• Mitigate permanent establishment (PE) risk in commercial contracts by correctly applying Article 5 of the OECD Model Tax Convention.
• Advise clients on treaty-based relief, including the application of Article 4 "tie-breaker" clauses to resolve dual-residency conflicts.
• Structure cross-border transactions to legally reduce withholding tax exposure on dividends, interest, and royalties.

Content 

The webinar will cover the following topics: 

• International Tax Developments and Trends
  • Recent developments in international taxation
  • Global tax reform and international tax initiatives
  • Key developments affecting South African taxpayers
  • Emerging international tax risks and trends
• Cross-Border Taxation
  • Taxation of cross-border transactions
  • Residence and source principles
  • Foreign income and cross-border activities
  • Double taxation considerations
• Tax Treaties
  • Overview and application of Double Tax Agreements (DTAs)
  • Treaty residence and allocation of taxing rights
  • Withholding taxes under tax treaties
  • Relief from double taxation
  • Treaty interpretation and practical considerations
• Transfer Pricing
  • Overview of transfer pricing principles
  • The arm’s-length principle
  • Cross-border related-party transactions
  • Transfer pricing documentation and compliance considerations
  • International transfer pricing developments
• International Tax Compliance and Risk
  • Key compliance obligations for taxpayers undertaking cross-border transactions
  • Common international tax risks
  • Tax authority scrutiny and audits
  • Penalties and interest arising from non-compliance
  • Practical considerations for tax practitioners
• Practical Application
  • Applying international tax principles to real-world scenarios
  • Identifying potential tax risks in cross-border arrangements
  • Practical considerations when advising clients on international tax matters

Obtaining your CPD certificate  

This training is compliant with the International Education Standard (IES7) issued by the International Federation of Accountants and recognised for CPD by relevant professional bodies including ACCA, CIMA, IAC, IIA, SAICA and SAIPA.   

All attendees are issued with a CPD certificate available in an online profile.  

About the presenter  

Adv Christel van Wyk 

Christel van Wyk is a General Tax Practitioner (SA) and a practicing Advocate in the Northern Cape, registered with The South African Institute of Taxation. With over 25 years of experience in both legal and tax fields, her expertise spans corporate international tax, tax avoidance, dispute resolution, and policy work. She has held key positions in both the private and public sectors, serving as a legal advisor to an international bank and a property company, and later leading significant roles at SARS, EY, SAICA, and the Office of the Tax Ombud. 

Christel's broad experience includes legislative submissions, tax dispute strategy, and heading various tax-related divisions. In 2023, she founded her own tax and legal practice. Academically, she holds a BA Law degree from the University of Stellenbosch, an LLB from UNISA, a Diploma in Taxation from the University of Johannesburg, and a Certificate in Mediation and Arbitration. 

Who should attend?  

The following persons will benefit from attending this webinar:  

• Practising accountants including: CA(SA), Professional Accountant (SA), AGA(SA), FCCA, BAP(SA), BA(SA) and ACCA.  

• Registered auditors.  

• Audit managers.  

• Trainee accountants.  

Price         

• R 450.00 - Online admission - Individual.  

• Group Price 1 - From R337 per person (up to 5 users)   

• Group Price 2 - From R260 per person (up to 10 users)   

• Group Price 3 - From R224 per person (over 11 users)  

Steps to register for the event:   

If you already have a profile, login and register for the webinar.  

If you don’t have a profile, create a free profile then login and register for the webinar.  

Click here to create a free profile (There is no charge to create a profile and gain access to our free Monthly Practice Management Series).  

Click here to find out about the Technical Resource Centre & CPD Subscription options.  

Additional material  

By attending this webinar you will be provided with:  

• A summarised slide presentation.  

• Reference documents and/or course material where available.  

• You can ask questions during the webinar and you will also have access to the presenter after the webinar.    

Corporate training solutions  

At SA Accounting Academy, we recognise the evolving needs of businesses in today's dynamic environment. Beyond our standard webinar offerings, we provide tailored corporate training solutions designed to empower your team with the latest in accounting and professional skills. Whether you're looking for online sessions or face-to-face training, our programs are crafted to ensure a comprehensive and engaging learning experience.   

Drawing inspiration from modern training methodologies, our corporate solutions are interactive, adaptable, and focused on real-world applications. We prioritise hands-on learning, ensuring your team can immediately apply their newfound knowledge in practical scenarios.   

Interested in a bespoke corporate training experience? Reach out to us at corporate@accountingacademy.co.za or call 010 593 0466. Together, let's design a training program that elevates your team's capabilities and aligns with your organisational goals.   

Contact us  

Have any questions or need any assistance? Contact us today!  

• Online chat through our website.  

• WhatsApp: Start chatting (+27635026114)  

• Phone: 010 593 0466  

• E-mail: ticket@accountingacademy.co.za