Employers & Experience: Namibian Mineral Corporation (Namco)
As internal tax advisor to the group Johan was responsible for the planning and managing of all the tax affairs and other regulatory issues of the Namco Group of companies. The group was involved in offshore diamond mining on South Africa's West Coast and Namibia's Coast.
As a result of its listing, diamonds sales, engineering requirements, financial requirements and a number of other managerial requirements, the company had interests in South Africa, Namibia, Angola, England, the Netherlands, Canada and Gibraltar, Johan's duties involved the management of all these taxation aspects.
Areas where Johan has been involved and had to furnish in-depth tax advice, were the following:
Direct taxes
- Take-over, which varied from proper structuring of the merger to an in-depth tax audit to ensure the necessary compliance
- Joint venture arrangements
- International treaty application, with reference to 'resident', 'permanent establishment', 'independent agents', 'professional services', etc.
- Transfer pricing of professional services, mining services, chartering and interest, with respect to South Africa, Namibia and England
- International tax planning taking the different Dutch structures into account
- Thin capitalization in respect of the South African companies
- Tax planning around foreign dividends, residence tax basis and capital gains tax
- Angolan tax risk management
- The acquisition of vessels, helicopters, airplanes, charter agreements and new mining equipment
- Sale and leaseback arrangements
- South African and Namibian mining taxation matters
- International finance arrangements
- Multi-currency management
- Captive Insurance
Employee's tax
- Structuring of packages
- International independent contractors and service companies
- Independent contractors
- Offshore allowances
- Expatriates
Indirect taxes
- South African VAT
- Namibian VAT
- Namibian Sales Tax
- Namibian Sales Levy
- Namibian Fuel Levies
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