Tax | vanbain 2026

vanbain
Tax

Clear, practical corporate and international tax advice - from compliance and governance to transactions, cross-border growth and SARS disputes.

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What practical tax advice should deliver

Tax affects more than the return filed after year-end. It shapes how a business funds operations, expands, restructures, rewards people, buys or sells assets, and responds to scrutiny. Effective tax advice must therefore connect the law to the commercial decision.

vanbain Tax identifies tax consequences early and focuses attention on the issues that matter, giving decision makers a clear view of the options, trade-offs and actions required.

Our role may be to review a transaction before terms are signed, strengthen a position before a return is filed, provide senior oversight to a growing tax function, or manage a SARS engagement once scrutiny begins.

Whatever the entry point, the objective is the same: a technically sound, commercially sensible and defensible outcome that supports the client's wider objectives.

How can vanbain Tax assist?

We provide focused advice on specific tax issues or coordinated support across the tax lifecycle.

Corporate Tax Advisory & Compliance

Compliance, technical advice and independent review of material tax positions.

Fractional Tax Director & Governance

Flexible senior tax leadership, governance and oversight without a full-time in-house tax director.

SARS Engagements & Disputes

Support through information requests, audits, assessments, disputes and voluntary disclosure.

International Tax & Cross-Border Expansion

Advice on residence, permanent establishments, treaties, withholding taxes and cross-border investment.

Transactions & Group Restructuring

Tax advice on acquisitions, disposals, funding, restructuring and implementation.

Pillar Two

Scope, data readiness, safe harbours, calculations and implementation support.

Global Mobility & Employment Tax

Cross-border employee and director tax, payroll and employer obligations.

Entrepreneurs, Family Offices & Trusts

Advice where personal, family, trust and business tax considerations intersect.

Who should speak to vanbain Tax?

We advise the people accountable for tax outcomes: boards, audit committees, CFOs, heads of tax and finance, CEOs, business owners, entrepreneurs and family offices. We work alongside internal teams and existing advisers, or provide direct support where senior in-house tax capacity is limited.

A conversation is particularly valuable when a business is:

• Expanding across borders. Entering a new market, bringing a foreign group into South Africa, or moving people, management or functions between jurisdictions.

• Transacting or changing structure. Acquiring, disposing, funding, restructuring, introducing investors or planning succession.

• Outgrowing its tax arrangements. Managing greater complexity without a full-time head of tax, or needing an independent review of material positions.

• Facing SARS scrutiny. Responding to a section 46 information request, verification, audit or assessment, pursuing a dispute, or considering voluntary disclosure of a historic default.

• Managing international or owner-level complexity. Considering residence, permanent establishment, place of effective management, withholding tax, offshore companies or trusts.

• Assessing Pillar Two. Determining group scope, data readiness, safe-harbour availability or potential top-up tax exposure.

The best time to obtain advice is usually before implementation. Where that opportunity has passed, the priority is to establish the facts, quantify the exposure, preserve the available options and choose a defensible path forward.

Why choose vanbain Tax?

Clients rarely need more tax information. They need judgment: what matters now, what can wait, what is defensible and what action should follow.

• Direct senior access. The person accountable for the advice remains involved in the facts, analysis, decisions and key client conversations.

• Perspective from all sides. Experience across SARS, Big Four advisory and commerce helps us anticipate how a position will work in the business and how it may be tested.

• Commercially usable advice. We explain the options, consequences and trade-offs in language that boards, CFOs and business owners can act on.

• Independent thinking. Advice is tailored to the client's objectives, commercial context and risk profile, without unnecessary layers or predetermined solutions.

• Connected capability. Tax, transfer pricing and legal specialists collaborate when the issues overlap, with roles and accountability kept clear.

• Implementation, not theory. We consider evidence, documentation, process and execution so that the position is not only technically sound, but capable of withstanding scrutiny.

• Long-term relationships. We take a genuine interest in the business and understand the commercial context in which tax decisions are made. That makes advice faster, more relevant and more useful.

About vanbain Tax

vanbain Tax is an independent corporate and international tax advisory business. We help businesses and private clients manage complex tax matters with clarity, sound judgment and a practical route forward.

We support clients across the tax lifecycle - from planning, structuring, compliance and governance to transactions, cross-border expansion, SARS engagements and disputes. Our advice is technically robust, commercially focused and designed to work in practice. We do more than explain the legislation: we identify the material issues, assess the options and help clients decide what to do next.

We advise listed and multinational groups, privately owned and fast-growing businesses, entrepreneurs, family offices and high-net-worth individuals.

Where a matter crosses disciplines, we work with vanbain Transfer Pricing and vanbain Legal to provide a coordinated response, with clear roles and accountability.

As part of the vanbain group, we share a common philosophy: independent advice, senior expertise and long-term client relationships. For us, tax is not the end product. It should support informed decisions, sustainable growth and defensible outcomes.

Expertise and Experience

vanbain Tax is led by Tracy Potgieter, CA(SA), a registered South African tax practitioner and corporate and international tax specialist with more than 25 years of experience across SARS, Big Four advisory and commerce.

• Big Four leadership. Tracy served as a Tax Partner at KPMG and EY, where she built and led specialist teams and advised major clients on corporate and international tax, financial services, transactions and restructuring.

• Revenue-authority insight. Her senior corporate income tax roles at SARS included legal and policy work, sector oversight and large-business tax risk, providing direct insight into how tax positions are identified, tested and challenged.

• Commercial experience. Her career also includes in-house roles at two major financial institutions, where she worked at the intersection of tax, governance, transactions, product design and commercial decision-making.

• Current advisory depth. She advises South African and multinational businesses, private groups, entrepreneurs and high-net-worth individuals across corporate tax, international tax, SARS disputes, transactions, governance and Pillar Two.

This combination enables vanbain Tax to view an issue through the eyes of the business, the external adviser and the revenue authority, and to translate technical complexity into practical decisions.

Where broader capability is required, we work with vanbain Transfer Pricing and vanbain Legal specialists to provide coordinated support without blurring professional roles.

Services

vanbain Tax provides clear, practical corporate and international tax advice across the tax lifecycle. Our work is senior-led, commercially focused and tailored to the client’s circumstances, internal capability and commercial priorities.

Corporate Tax Advisory & Compliance

Corporate income tax compliance, technical advice and independent senior review of material tax positions. We support provisional tax, corporate income tax returns, assessed losses, capital allowances and the treatment of material or unusual transactions.

Our focus is not simply on filing. We help identify issues early and ensure significant tax positions are properly considered, documented and supportable.

Fractional Tax Director & Tax Governance

Flexible senior tax oversight without the need for a full-time in-house tax director. We support tax-risk reviews, material transactions and strategic decisions, board and audit-committee reporting, policies and controls, SARS relationship management, adviser coordination and ongoing support to CFOs and finance teams.

International Tax & Cross-Border Expansion

Advice on the tax consequences of operating, investing and expanding across borders, including permanent establishments, place of effective management, individual and corporate tax residence, treaty application, withholding taxes, offshore structures and inbound and outbound investment.

We help clients understand how the tax rules apply to the proposed commercial model and identify practical issues before implementation.

Transactions & Group Restructuring

Tax advice on acquisitions, disposals, corporate reorganisations, funding arrangements and changes to group structures.

We support pre-transaction planning, CGT and base-cost analysis, buy-side and vendor tax due diligence and implementation, with a focus on ensuring that the intended tax treatment is technically supportable and reflected consistently in the transaction and supporting documentation.

SARS Engagements & Disputes

Support through section 46 information requests, verifications, audits, assessments, objections, appeals, alternative dispute resolution and voluntary disclosure.

We help clients establish the facts, assess the technical position, quantify the exposure and determine the most appropriate response. Where appropriate, we work with vanbain Legal or specialist counsel on matters requiring legal input, privilege, dispute strategy or representation.

Pillar Two, Global Mobility & Specialist Tax Matters

Practical support for multinational groups assessing and managing the impact of the global minimum tax rules.

We also advise on the tax consequences of employees, executives and directors working across borders, including individual tax residence, payroll and shadow payroll, employees’ tax and related employer obligations. We help businesses identify obligations early and align the tax and payroll treatment with where people work, how they are remunerated and the roles they perform.

For entrepreneurs, family offices and private clients we advise on a number of matters including tax residence and cessation, onshore and offshore trusts, funding arrangements, attribution rules, succession-related transactions and the interaction between personal, trust and corporate structures.

Contact Us

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Contact vanbain Tax Director Tracy Potgieter, at tracy@vanbain.com

Email Tracy

vanbain Tax

About vanbain Tax

Services

Corporate Tax Advisory & Compliance

​Fractional Tax Director & Tax Governance

SARS Engagements & Disputes

Contact Us

vanbain
Tax

Fractional Tax Director & Tax Governance