Skip to content

Annalie Pinch

Senior Consultant | Cape Town

Quick Search

Contact

T: +27 21 480 7819

Overview

Annalie is a dedicated team player with extensive and solid experience in taxation, having worked in the income tax consulting environment for more than 20 years, both at legal and accounting firms.

Annalie’s area of expertise is corporate income tax, including advising on domestic income tax matters, cross-border transactions, inbound and outbound investments, the tax efficient planning of corporate acquisitions and restructures and advising and/or assisting clients in their dealings with the South African Revenue Service (“SARS”). She also advises local and foreign corporates on South African exchange control matters.

Experience

  • Advising on the income tax implications of restructure transactions (i.e. mergers, acquisitions, disposals, corporate and/or tax redomicile) of clients in various industries including investment holding, financial services, logistics services and retail;
  • Performing vendor and buyer due diligence reviews, preparing due diligence reports and making recommendations in relation to tax risks identified;
  • Requesting advance tax rulings from SARS on behalf of clients in respect of a variety of income tax matters and related interactions with SARS;
  • Preparing tax opinions to banks and/or preference share issuers on the application of sections 8E and 8EA of the Income Tax Act in the context of preference share transactions, including attending to researching the pertinent technical issues and reviewing and commenting on term sheets and agreements from an income tax perspective;
  • Performing “net income” calculations in respect of the “controlled foreign companies” of South African multinational groups;
  • Performing “place of effective management” reviews;
  • Advising on whether activities performed by individuals based in South Africa constitute a “permanent establishment”;
  • Advising on the South African tax implications of cross-border transactions, including withholding taxes and the application of double tax agreements, the multi-lateral instrument and exchange control considerations;
  • Providing assistance and guidance to taxpayers in various industries in respect of requests for information from SARS, SARS audits and letters of findings issued by SARS;
  • Providing South African exchange control advice such as commenting on the application of the relevant regulations and practices of the Financial Surveillance Department of the South African Reserve Bank (“SARB”) and/or assisting with the preparation of applications to SARB; and
  • Providing comments to SARS and National Treasury in respect of proposed tax changes and attending to submissions regarding technical corrections required.

* Experience gained prior to joining Bowmans

AREA OF EXPERTISE

Tax

Qualifications

  • MCom (Taxation) – University of Pretoria
  • BCom (Taxation) (Hons) Financial Management Sciences (Tax) – University of Pretoria
  • LLB (cum laude) – University of Pretoria
  • B Com (Law) – University of PretoriaProfessional Membership

Overview

Annalie is a dedicated team player with extensive and solid experience in taxation, having worked in the income tax consulting environment for more than 20 years, both at legal and accounting firms.

Annalie’s area of expertise is corporate income tax, including advising on domestic income tax matters, cross-border transactions, inbound and outbound investments, the tax efficient planning of corporate acquisitions and restructures and advising and/or assisting clients in their dealings with the South African Revenue Service (“SARS”). She also advises local and foreign corporates on South African exchange control matters.

Experience

  • Advising on the income tax implications of restructure transactions (i.e. mergers, acquisitions, disposals, corporate and/or tax redomicile) of clients in various industries including investment holding, financial services, logistics services and retail;
  • Performing vendor and buyer due diligence reviews, preparing due diligence reports and making recommendations in relation to tax risks identified;
  • Requesting advance tax rulings from SARS on behalf of clients in respect of a variety of income tax matters and related interactions with SARS;
  • Preparing tax opinions to banks and/or preference share issuers on the application of sections 8E and 8EA of the Income Tax Act in the context of preference share transactions, including attending to researching the pertinent technical issues and reviewing and commenting on term sheets and agreements from an income tax perspective;
  • Performing “net income” calculations in respect of the “controlled foreign companies” of South African multinational groups;
  • Performing “place of effective management” reviews;
  • Advising on whether activities performed by individuals based in South Africa constitute a “permanent establishment”;
  • Advising on the South African tax implications of cross-border transactions, including withholding taxes and the application of double tax agreements, the multi-lateral instrument and exchange control considerations;
  • Providing assistance and guidance to taxpayers in various industries in respect of requests for information from SARS, SARS audits and letters of findings issued by SARS;
  • Providing South African exchange control advice such as commenting on the application of the relevant regulations and practices of the Financial Surveillance Department of the South African Reserve Bank (“SARB”) and/or assisting with the preparation of applications to SARB; and
  • Providing comments to SARS and National Treasury in respect of proposed tax changes and attending to submissions regarding technical corrections required.

* Experience gained prior to joining Bowmans

Keep up to date on the latest news

Our specialist practitioners share their knowledge and insights into a range of legal issues through various public speaking engagements, publications and media interactions. Subscribe to our legal updates to keep abreast of new developments.