The South African government intends promoting South Africa as a gateway for investment into Africa. This will necessitate some important changes being made to South Africa's legal and tax framework. It is envisioned that the proposed investment in Africa and South Africa would take the form of holding companies incorporated in South Africa and holding interests in operating subsidiaries located in South Africa or the rest of Africa. This article refers specifically to the creation of tax regimes that are attractive the establishment of holding companies, and investigates how three countries - Belgium, Ireland and the UK - have struggled to put in place such systems. The article goes on to compare these jurisdictions with two others that have had greater success, viz the Netherlands and Mauritius. The article concludes by identifying some lessons that could be learned by South Africa from the respective experiences of the countries whose tax regimes are discussed in the article.
This article is an adapted version of a section of the research done and submitted
by the author in part fulfillment of the requirements for a doctoral degree at the
University of Pretoria.