Brenda Engelbrecht
Edenvale,GP
Summary
I have a deep understanding of the South African controlled foreign company provisions and how these interplay with transfer pricing. In addition, I have a deep understanding of transfer pricing principles across multiple jurisdictions and how the assessments under these provisions interact with contractual commitments and other tax types. I use this understanding of the law to proactively manage tax positions that are being taken and to defend those positions when questioned by tax authorities. I have a strong capability of directing tax audits in a way that one achieves the expected outcome i.e. minimal to no cash tax outflows. I enjoy and spend a substantial amount of time reading and keeping myself technically up to date across multiple jurisdictions, predominantly in international tax principles. I don’t read summaries of case law but read the case too and develop my own opinion based on what I have read. This extends to monitoring changes in tax law itself. In addition to being technically strong, I have a reputation of being able to explain the complexities to non-tax colleagues, across the management spectrum, in a way that is understandable for them. I firmly believe in diversity and inclusivity within a team and across teams and gain personal joy from mentoring junior members of my team so that they become well rounded tax professionals.
Overview
31
31
years of professional experience
1
1
Certification
Work History
Group Head of Tax
Aspen Pharmacare Holdings
02.2012 - 06.2024
- I am accountable for developing and implementing the overall Group Tax strategy, policies, procedures and for providing advisory services across all major tax types for mergers and acquisition activities and for legal entities in the Group (56 countries)
- My main focus has been based on international tax and transfer pricing, also taking into account the impact that positions taken in other tax types impact on these positions
- The following activities are core to the work that I undertake: Developing tax efficient proposals for M&A activities and supporting the senior leadership team throughout the transaction lifecycle, Developing a maintaining well balanced, transparent reporting of taxes in the Group’s integrated report and annual financial statements, Designing and implementing the Group’s transfer pricing policies and documentation to effectively manage risk across all jurisdictions and strategically monitoring changes in global transfer pricing law to enhance these and minimize risk, Managing and subsequently overseeing the IFRIC23 provision for transfer pricing, Overseeing the implementation of the Group’s transfer pricing policies and reporting obligations, Overseeing the management of the Group’s corporate tax compliance, Overseeing the management of tax audits launched against the Group, and actively participating in the strategic approach to be taken in relation to high-risk transfer pricing audits, Overseeing the automation of indirect, direct and transfer pricing, Managing a team of 11 tax professionals, including mentoring them to become future tax leaders
Senior Tax Manager
Anglo American South Africa
08.2008 - 01.2012
- Relationship manager for the Anglo Platinum Group including providing advisory services on projects and overseeing the management of the Group’s compliance, Responsible for managing the tax affairs for the SA Group’s controlled foreign companies based in Africa, Luxembourg, UK, Australia, Chile, Brazil, and Hong Kong amongst other jurisdictions, Responsible for reviewing UK controlled foreign company returns, Participating in Group wide projects including disposal and transfer pricing projects, Engaging with National Treasury to amend tax law, Managing three reports
Senior Corporate Tax Manager
E&Y
01.2007 - 08.2008
- Tax advisory services to corporate clients, Tax accrual review management as part of the external audit function, Tax return reviews, Clients: Investec Group, UBS Bank, ABN Amro Bank, TFS Securities, Louis Dreyfus Commodities, Reckitt Benckiser, Proctor and Gamble, Saab Grintek, Transnet
Lecturer in Taxation
University of the Witwatersrand
06.2004 - 12.2006
- Assisting with the fourth year taxation course for the BAcc degree, Prepared and presented taxation lectures for third-year students (topics: individuals, fringe benefits) and fourth-year students (topics: residence-based tax, non-residents, foreign exchange, financial instruments, administration, and anti-avoidance provisions, group provisions, dividends, and STC), Prepared and ran tutorials for the fourth-year group on all topics covered in the fourth year of studies, Setting and marking exam question for the third and fourth ear taxation program, Grading research reports and exam question for the Taxation Honours program, Marking SAICA board papers, Contributing to Silke on Tax (handbook and main literature)
Managing member of accounting and tax service provider
Rosebank Accountants cc
01.1993 - 12.2001
Education
Master of Commerce (Taxation) -
University of the Witwatersrand
01.2000
Honours Bachelor of Accounting Science -
University of the Witwatersrand
01.1996
Bachelor of Commerce (Financial Accounting and Economics major) -
University of the Witwatersrand
01.1994
University entrance matric pass -
University of the Witwatersrand
01.1989
Skills
- Technically competent in OECD transfer pricing principles and domestic transfer pricing law in several countries including South Africa, Kenya, Tanzania, Nigeria, Mauritius
- Analysing transactions to determine appropriate transfer pricing positions that should be taken in relation to those transactions
- Defending transfer pricing positions when subject to tax authority audits
- Preparing commercially relevant advice using a collaborative approach with fellow professionals and business
- Determining transfer pricing positions required for treasury functions (developed and implemented this and a transition to a new operating model)
- Working with IBFD to support them in their transfer pricing initiatives (training and opinion material)
- Implementing documentation database that was used to create transfer pricing documentation, questionnaires for business and review notes for team members to prepare documentation
- Creating transfer pricing documentation standards with support of advisors and thereafter maintaining them
- Preparing the master file and transfer pricing policies
- Creating and delivering transfer pricing training for team members and the broader organisation
Accomplishments
- Awarded the Aspen Diversity, Inclusion and Innovation award in 2018 and the Chairman’s Award for Woman Leadership in 2015
- Promoted to Senior Tax Manager at Anglo American, within nine months of joining
- Successfully argued and eliminated an adverse BEPS assessment for the Aspen group (R6,5bn tax liability at the time of the adverse assessment)
- Successfully managed the interview of 75 employees to defend Aspen against the BEPS assessment (including the Group CEO)
- Effectively managed transfer pricing audits in Germany, France, Tanzania, Australia, Kenya, USA, Brazil with a maximum settlement of under EUR2m across all of these audits (overall success rate in transfer pricing audits over 99%)
- Successfully minimized tax arising on international transactions that are entered into (0% to 10%)
- Tax structuring applying international tax and transfer pricing principles
- Automating transfer pricing using Oracle tax reporting
- Automating controlled foreign company returns
- Negotiating changes in tax law in South Africa with National Treasury
Coursescertifications
- London School of Economics and Political Science – MBA Essentials with a focus on finance and economics - 2021
- Executive leadership coaching – 2019, 2021
- Gibbs - Managing projects strategically – 2020
- Gibbs - Strategy, innovation and design thinking - 2020
- Gibbs - Strategy for Non-strategists – 2020
- Gibbs – Performance management fundamentals - 2014
- Gibbs - Leadership and people management – 2012
- The Beufort Institute - financial instruments – 2007
- EY Tax Learning – Learning Leader - 2007
- University of the Witwatersrand - The Teaching Role - 2004
- The Pacific Institute investment in excellence – 2000
Valuesstrengthsmotivators
I value being part of a diverse and inclusive team which interact with one another based on equality, empathy, integrity and trust. I am detail orientated and value undertaking meaningful work for the benefit of the greater organization with enthusiasm.
I am a coaching, participative and maternalistic leader who treats everyone firmly but fairly. I encourage curiosity, bravery and perseverance. I listen carefully and am able to apply perspective to things that I am exposed to which allows me to form an opinion which I resonate with others to then look at implementing.
I enjoy seeing success and being exposed to varying work that offers challenge.
Affiliations
- South African Institute of Taxation
Certification
- [Area of certification] Training - [Timeframe]
Additional Information
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Timeline
Group Head of Tax
Aspen Pharmacare Holdings
02.2012 - 06.2024
Senior Tax Manager
Anglo American South Africa
08.2008 - 01.2012
Senior Corporate Tax Manager
E&Y
01.2007 - 08.2008
Lecturer in Taxation
University of the Witwatersrand
06.2004 - 12.2006
Managing member of accounting and tax service provider
Rosebank Accountants cc
01.1993 - 12.2001
Master of Commerce (Taxation) -
University of the Witwatersrand
Honours Bachelor of Accounting Science -
University of the Witwatersrand
Bachelor of Commerce (Financial Accounting and Economics major) -
University of the Witwatersrand
University entrance matric pass -
University of the Witwatersrand
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