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Group Tax Consolidation and Intercompany Loan Structuring

Groups move funds and share costs across entities, and each intercompany flow carries tax consequences. Poorly structured loans and charges attract adjustments and withholding taxes. This programme helps group finance teams structure and document these flows.

What you will be able to do

  • Map the tax touch points of common intercompany flows
  • Structure intercompany loans on arm length terms
  • Document interest, fees and cost recharges
  • Manage withholding tax on cross border flows
  • Prepare records that support the group position on review

Course outline

  1. 01Intercompany flows and their tax effects
  2. 02Arm length principles for loans
  3. 03Interest rate and thin capitalisation considerations
  4. 04Cost recharges and shared services
  5. 05Withholding tax on cross border payments
  6. 06Documentation and agreements
  7. 07Managing group tax risk

Who should attend

Group tax managers, treasury staff, financial controllers and accountants in multi entity groups with significant intercompany activity.

Dates, venues and fees

DatesVenueDaysFeeCalendar
17 to 19 Aug 2026Cairo3US$1,500
24 to 26 Aug 2026Accra3US$1,500
31 Aug to 2 Sep 2026Lusaka3US$1,500
7 to 9 Sep 2026Kigali3US$1,500
14 to 16 Sep 2026Nairobi3US$1,500
21 to 23 Sep 2026Durban3R13,000
28 to 30 Sep 2026Johannesburg3R13,000
12 to 14 Oct 2026Mauritius3US$1,500
19 to 21 Oct 2026Dubai3US$1,500
26 to 28 Oct 2026Lagos3US$1,500
2 to 4 Nov 2026Harare3US$1,500
9 to 11 Nov 2026Kampala3US$1,500
16 to 18 Nov 2026Dar es Salaam3US$1,500
23 to 25 Nov 2026Pretoria3R13,000
30 Nov to 2 Dec 2026Cape Town3R13,000
14 to 16 Dec 2026Online3US$900
21 to 23 Dec 2026Mozambique3US$1,500

Fees are per delegate. South African venues are priced in rand; other locations and online in US dollars. Fees exclude 15% VAT where applicable. Group bookings of three or more delegates from the same organisation qualify for a reduced rate; contact us for a quotation.

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