Webinar | Foreign Pension Schemes: There be Dragons - CPD Consortium

Foreign Pension Schemes:

There be Dragons

Date:

6 November 2025

Time:

10:00 - 11:30

Platform:

Zoom

Cost:

R180

CPD Points:

1.5

Registration is closed

Foreign pension earners stand to be significantly impacted by the recent proposed amendments to s10(1)(gC). Prof Des will discuss this legislation and the implications of the proposed amendment for foreign pension earners.

There are a number of foreign pension schemes that have made offerings to South African residents. The tax implications that arise in consequence of South African residents participating in these retirement offerings are complex and, in some respects very uncertain. 

These foreign pension schemes are in the main structured as a trust arrangement, with the South African participants being either discretionary or vested beneficiaries. 

While not stricto sensu a cell structure as commonly understood, in essence the financial position of each participant is accounted for in a bespoke account.  This bespoke account will comprise the contributions made by the participant and any growth in the value of such contributions. Any retirement benefits paid to the participant will accordingly be accounted for in the bespoke account, and the participant’s retirement benefits will always be limited to the amount standing to the credit of the participant in his or her bespoke account. 

Generally, participants are entitled to annuities or lump sums on the happening of specified events, such as attainment of an age, death or termination.  There is a large degree of discretion as regards the nature (annuities/lump sums) and timing of the payments (regular/once-off/yearly), with the participants able to request a certain payment regime, but generally subject to the absolute discretion of the trustees of the scheme. 

While the rules of each foreign pension scheme are naturally different, the rules are nevertheless also very similar when it comes to the rights and obligations of the foreign pension scheme and participants. 

Key topics

In this session, the following key topics will be discussed: 

  • The legal construct of foreign pension schemes offered to South African residents.
  • The nature and deductibility of "premiums" paid to foreign pension schemes.
  • South African tax status of lump sum or periodic "pensions" paid to South African residents.
  • A discussion on the proposed amendments to s10(1)(gC)
  • Q&A
Registration is closed
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Who Should Join?

Tax Practitioners & Advisors

Accountants & Auditors

Compliance Officers

Legal Advisors

Financial Managers

About The Speaker

Prof Des Kruger was previously a Partner, and now Consultant, in the Tax Practice at Webber Wentzel Attorneys. He has studied law and tax at the universities of KwaZulu Natal and Wits in South Africa, and Harvard in the United States of America. Des is presently an Adjunct Professor at the University of Cape Town (Law Department) where he lectures in value-added tax (VAT) at the postgraduate level. 

Des has specialised in all aspects of taxation, including international tax, corporate tax and value-added tax, for more than 46 years. During that time he spent 12 years in total at Inland Revenue/South African Revenue Service, where he was a Deputy Director (Legal Drafting) and then subsequentely a Specialist in the then Legal and Policy Division. He has co-authored Value-Added Tax in South Africa and Broomberg on Tax Strategy and is currently co-editor of Business Tax and Company Law Quarterly. 

Des’ expertise has been recognised by various international research organisations including Chambers Global and the prestigious International Tax Review. He has also been named as one of the top tax consultants in South Africa by the International Tax Review and was named as Lawyer of the Year: Tax, 2010 by Best Lawyers. 

Des has Advised both Margo and Katz Tax Commissions of Enquiry into the Tax System of South Africa, and was a member of the VAT Ad-hoc Committee of the Davies Tax Committee. 

Gain clarity on how SARS views foreign pension schemes and ensure your clients’ cross-border retirement structures remain compliant.

#ForeignPensionSchemes  #TaxCompliance  #CrossBorderTax  #SARS #Taxation  #SouthAfricaTax#CPD 

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Professor Deborah Tickle

FROM THE DAVIS TAX COMMITEE
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Keitumetse Sesana

TAX TECHNICAL SPECIALIST AT SAIT

Keitumetse Sesana is a registered SARS practitioner who also holds the designation of Master Tax Practitioner from the South African Institute of Taxation. With a solid background in international corporate tax matters from her previous roles at KPMG South Africa, she contributes important insights to the development of tax policy across various areas.  

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Keitumetse holds a Master of Laws (LLM) specialising in Tax Law, a Bachelor of Laws (LLB), and a Bachelor of Commerce (BCom) Law degree. Keitumetse is passionate about contributing to and transforming the tax legislative landscape. 

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Delano Abdoll

Admitted Attorney, BA (Law), LLB, LLM at Tax Consulting SA

Delano is a highly skilled attorney admitted to the High Court of South Africa, with extensive knowledge and expertise in tax law. He holds a Bachelor of Arts in Law, a Bachelor of Laws, and a Master of Laws degree in Procedural Law, all obtained from the University of Pretoria. Delano has a strong focus on expatriate tax and individual cross-border taxation, making him an expert in dealing with complex tax issues faced by individuals who work or reside across international borders. With his comprehensive understanding of tax laws and regulations, he is able to provide exceptional advice and support to clients in need of expert tax planning and management.

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Tertius du Plessis

Professional Accountant and Crypto Taxpert

Tertius is a seasoned expert in the fields of finance and taxation, with a specialised focus on the realm of cryptocurrencies. His portfolio includes accounting services for a diverse range of clients, including individuals, private companies (Pty) Ltd’s, trusts, and deceased estates. He boasts a Bachelor of Accounting (BAcc) degree and has spent eight enriching years in the blockchain/cryptocurrency sector. In his role as a CryptoTaxpert, Tertius skillfully navigates clients through the intricacies of transitioning between fiat currency and cryptocurrency. His extensive knowledge of cryptocurrency, blockchain technology, trading, and HODLing, positions him as a reliable interpreter and manager of crypto data. Tertius’ profound understanding of South African cryptocurrency tax regulations equips him to deliver SARS-compliant, optimised crypto tax reports. He is dedicated to helping clients manage their crypto assets and ensuring a seamless flow of funds. He lives by the philosophy, “My compensation is not for the hours I put in, but for the value I deliver in those hours.” He believes that “What you pay is the price, what you gain is the value.” As a #CryptoTaxpert, his mission is to deliver unparalleled value to his clients.

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Piet Nel

CA (SA) Specialising in taxation

Piet Nel is a CA (SA) who specializes in taxation. He was previously the Project Director of professional development (tax) at SAICA, and the project director for tax at SAICA.  Before joining SAICA again, he was involved in tax consulting and tax dispute resolution. 

He is an accounting member of the Tax Court, second term. He is a visiting adjunct professor at Wits and was previously a lecturer in tax at the University of Pretoria to students doing a Master’s degree and at UNISA at postgraduate level.

He was a member of SAICA’s national tax committee and is still quite active in the development of tax legislation in South Africa by commenting on proposed legislation. Over a period of more than three decades, he presented numerous tax seminars and workshops to tax practitioners.

He regularly speaks on radio and TV and publishes tax related articles.He is involved, as a member of the SAICA’s Examination Committee, in setting the examination to test initial competence for prospective CA (SAs).

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Sophia Steyn

Admitted Attorney and legal advisor

Sophia Steyn is an experienced attorney with a strong background in will drafting, trust administration, and estate administration. With ten years of legal practice experience, including owning and managing her own practice, Sophia brings valuable management skills and a client-focused approach to her work. Currently employed at Rauch Gertenbach Inc., she specialises in drafting wills, establishing trusts, administering estates. Sophia’s expertise, professionalism, and commitment to exceptional client service make her a trusted legal practitioner in her field.

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Jerry Botha

Managing Partner
at Tax Consulting SA

Jerry Botha commenced his tax career in United Kingdom / United States Tax and served articles at McCorkindale & Holton’s London office. After being with the Big-4 accounting firms, in 2005 he started his own niche tax practice.

Tax Consulting South Africa has grown over the years to the largest independent tax practice in South Africa, which specialises in the most complex areas of tax planning and compliance. The firm is SARS recognised as a top 6 tax practice and a leading advisor to large multinational corporates, globally mobile individuals, high net worth professionals and families; but also fellow professionals on complex areas of South African and international tax.

Tax Consulting South Africa authored LexisNexis’ “Expatriate Tax” textbook, as critically acclaimed by the esteemed Judge Dennis Davis. The textbook is now in its 2nd edition.

Jerry enjoys a collaborative approach with fellow professionals, continuous professional development, commenting on legal development and growing the next generation of professionals.

 

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Catherine Fourie

HEAD OF CPD CONSORTIUM

Catherine is a Chartered Accountant (CA(SA)) and tax practitioner who completed her articles at Deloitte in 2003. After three secondments to the United States of America and Canada, she rejoined Deloitte as audit manager for four years, whereafter she has been a lecturer on the BCom Accounting programme with the Nelson Mandela University for 15 years until early 2024. Her main subjects were Taxation, Auditing and Ethics and Corporate Governance, as well as lecturing on the MCom (Taxation) program. She has a deep passion for teaching to which she has dedicated most of her professional career, especially fundamental principles. She implemented innovative learning and teaching practices, both online and hybrid/flexible; always ensuring impactful learning. As a member of the SAICA Digital Acumen Working Group she has always been passionate about innovation and resilience, which are both essential for the sustainability and growth of the modern professional. With the many students which have been through her lectures, she is excited to now bring digital innovation to the upskilling of professionals who work in the ever-changing landscape of tax and accounting. Her approach and style is one of ensuring a sound technical base, from where she quickly makes tax and accounting highly practical and relevant; delivering immediate value for anyone attending her training sessions.

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Sidney Fletcher

Senior Manager of Trust and Deceased Estate Compliance at Tax Consulting SA

Sidney is a versatile and results-driven qualified Senior Tax Practitioner. He has more than 20 years of experience working for SARS and was responsible for Taxpayer Education for a big part of that period. He is a dedicated professional with extensive knowledge and his affinity for Individual Taxes makes him an excellent tax planner and skilled at tax optimisation. Committed to the best care for clients through transparent communication. Skilled in negotiation with a strong ability to problem solve to assist clients with tax problems.

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Roxshanna du Toit

Independent Trust and Fiduciary Services Expert & CPD Project Coordinator

Roxshanna is a seasoned tax professional and was until February 2024 the Head of Tax, Standard Trust Limited. As one of the market’s largest leading fiduciary services providers, she worked daily on complex matters pertaining to tax and accounting for trusts, deceased estates and the commercial and family interests which necessarily comes therewith. She has a BCom (Taxation Honours) and also served as a lead representative for the Banking Association of South Africa (BASA) in providing input to SARS directly as impacts the fiduciary arena. Her interest sphere is streamlined solutions to overcome the administrative and operational challenges of trustees, accountants, tax practitioners and executors. She considers herself as a practical generalist who excels in getting the job done, and she has been involved in untangling, resolving and ensuring compliance of some of the largest and most complex South African and international trusts, estates and family structures. Her decision to start her own practice allows her to expand her professional horizon as well as spend more quality time with her son.