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 09h00 to 11h00 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.

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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: 

•  South African Residency, Source Rules, and Cessation Trends

  • Worldwide vs. source tax frameworks in South African law

  • Domestic residency mechanics: physical presence vs. ordinarily resident tests

  • The expatriate cessation process and exit tax implications

  • Statutory vs. common law source of income rules

• Double Tax Agreements and the New Transfer Pricing Framework

  • Treaty status and integration under section 108 of the Income Tax Act

  • The Article 4 Tie-Breaker clauses and resolving residency conflicts

  • Permanent establishment (PE) risk and commercial operations

  • The newly deployed SARS Advance Pricing Agreement (APA) programme

• Income Classification, Withholding Taxes, and Treaty Relief

  • Business profits under Article 7 of the OECD Model Tax Convention

  • Passive income mechanics: withholding taxes on dividends, interest, and royalties

  • Employment income and the 183-day rule under Article 15

  • Claiming double taxation relief and section 6quat tax rebates

• The Global Tax Shift and SARS Compliance

  • The Global Minimum Tax Act of 2026 and Pillar Two principles

  • Local Top-Up Tax application to South African entities

  • SARS eFiling reporting obligations and automated risk profiles

  • OECD administrative compliance and international exchange of information

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: 

• Advocates. 

• Attorneys. 

• Corporate Legal Professionals. 

• Legal academisc. 

• Candidate attorneys. 

• Law students. 

• Paralegals. 

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. 

About SA Legal Academy 

Welcome to SA Legal Academy (SALA), a provider of courses to help you succeed in your chosen career. We are committed to providing our students with the highest quality training and support, to ensure that your skills and knowledge are up to date and ready to face the challenges of the modern workplace. Our courses are designed to ensure that you reach your professional goals and enhance your career prospects. With our experienced training staff and comprehensive resources, you can be confident that you will receive the highest quality of training from SA Legal Academy. 

SALA is a Level 2 B-BBEE contributor, with 125% procurement recognition. Training spend on certain solutions can be allocated against the Skills Development element of the B-BBEE Scorecard through accredited and nonaccredited training or claimed through SETA grants. In addition, 25% of your Skills Expenditure can be claimed on non-accredited training or courses. 

Corporate Training Solutions 

At SALA, 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 legal 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 prioritize 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 [email protected] or call 012 941 0448. Together, let's design a training program that elevates your team's capabilities and aligns with your organisational goals. 

Contact Us For More Information 

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

• Online chat through our website.  

• Phone: +27 (0) 12 941 0448  

• E-mail: [email protected]