Controlled Foreign Companies (Section 9D) and Cross-Border Trading: A Practical Masterclass

  • Presenter: Ettiene Retief
  • Level: Advanced
  • Study time: 2 Hours
  • Date: 22 October 2026
    08:00 - 10:00 
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Course overview

South African businesses are increasingly operating through foreign companies, regional subsidiaries, offshore trading structures and international investment vehicles. These structures can, however, trigger the complex Controlled Foreign Company rules contained in section 9D of the Income Tax Act.

This practical masterclass will unpack when a foreign company becomes a CFC, how participation and voting rights are determined, and when the net income of a foreign company may be attributed to South African residents. Particular attention will be given to the foreign business establishment exemption, diversionary income rules, high-tax exemptions and common cross-border trading structures.

The webinar will demonstrate how section 9D applies to foreign operating companies, sales and distribution businesses, service companies and group structures. It will also highlight common compliance risks and the interaction between CFC rules, transfer pricing, foreign tax credits and international tax planning.
In completing this learning engagement, you will have developed the following professional competencies indicated in the green section below:

What's included?

  • 1 Live event
  • 1 Quiz
  • 1 Certificate

Section 9D

Link with SAICA Competency Framework

  • Competencies covered in Enabling and future competencies groups and Technical competencies