In order to make South Africa an ideal location for multinational enterprises wishing to invest in Africa, a regional headquarter (HQ) company regime has been introduced vide the Taxation Laws Amendment Act of 2010. The regime is intended to address some tax barriers to the setting up of regional holding companies in South Africa. These barriers include: -   controlled foreign company (CFC) rules; -   dividends taxation; and -   transfer pricing (and thin capitalization) rules. Definition For a resident company to qualify as an HQ company: -   each of its shareholders must, throughout the tax year, hold...