Issue 2012

This edition includes 4 case studies with a range of international clients across a variety of market sectors: precision metalworking, lift and elevator manufacturing, contract research and not-for-profit.

UHY strengthens presence in Asia

Global accountancy network UHY extends its coverage within Asia by appointing Yongyuth Accounting and Son Co. Ltd and its affiliate firm, Saman Audit and Corporate Services Co. Ltd.

Yongyuth Accounting and Son Co. Ltd. was established in 1967 with a history spanning over two generations and nearly four decades. With three partners and a team of 25 staff, the firm, based in Bangkok, provides tax, bookkeeping and company secretarial services focussing on the business needs of clients covering a variety of sectors such as trading, manufacturing, entertainment and construction. 

Managing partner, Panit Mokarakorn, says: “We joined the UHY network for a number of reasons. The global presence of the network combined with the expertise and knowledge of UHY’s people around the world not only strengthens our own capabilities, locally and internationally, but also these of our clients and their operations. We strongly believe that our membership of the UHY network will not only create great opportunities for the ASEAN Economic Community (AEC), but also on a more global scale in the future.”

John Wolfgang, chairman of UHY commented: “We are delighted Yongyuth Accounting and Son Co. Ltd. and its affiliate have joined the UHY network extending our coverage and capabilities in Asia. The firm’s admittance to the UHY network will add a great deal of regional market and sector expertise. We strongly believe the firm is a very good fit for our network.”

 

UHY strengthens presence in the Americas

Global accountancy network UHY extends its coverage within the Americas region by appointing UHY Botello & Marquez S.A.

UHY Botello & Marquez S.A. was established in 2008. With a team of 7 staff and two partners, the firm is based in Panama City. With client operations in South, Central and North America, UHY Botello & Marquez S.A. provides the full range of audit, accounting, tax advisory, management consultancy and legal services. The firm has a portfolio of clients in a variety of sectors such as technology and software, services, retail and wholesale, energy, and hospitality and health. 

Managing partner, Diógenes E. Botello says: “We have joined the UHY network for a number of reasons. Being a part of a well recognised and reputable international network is very exciting for us. The global presence of the network combined with the expertise and knowledge of UHY’s people around the world not only strengthens our own capabilities, locally and internationally, but also these of our clients and their operations. We look forward to elevating our business through a successful cooperation with other firms operating within the UHY network.” 

John Wolfgang, chairman of UHY commented: “We are delighted UHY Botello & Marquez S.A. have joined the UHY network extending our coverage and capabilities in the Americas region in this key geographic and economic location. The firm’s admittance to the UHY network will bring strong regional market and sector expertise, enhancing our capabilities in this region. We strongly believe the firm is a very good fit for our network.”
 

The world’s fastest-growing middle class

Investor and philanthropist George Soros has described it as ‘one of the few bright spots on the gloomy global economic horizon’. 

China’s latest GDP forecast? Growth from one of the Asian tiger economies, maybe?

No. Soros is talking about Africa. It’s a continent wracked by poverty, where electricity is intermittent, where corruption soaks up development funding, where political instability and tyrannical governments undermine confidence, and where kidnapping of Westerners is rife. Or, at least that’s been the stereotypical image of African countries till now among Western investors. The Chinese have invested in Africa’s natural resource extraction for more than a decade, but it is only more recently that other international investors are waking up to the potential from Africa’s imminent boom in consumer spending, which is set to rise from USD 860 billion in 2008 to USD 1.4 trillion in 2020, according to the McKinsey Global Institute.

Growth in business technology across the continent is leading the way.

The International Civil Aviation Organization expects Africans to fly 8.3% more miles in 2012, making the continent one of the fastest-growing markets for air travel behind Asia and the Middle East. 

New five-star hotels are being constructed: currently 10 in Lagos, Nigeria, alone. Prices for apartments in fashionable districts of Lagos match those of Western cities. 

Growth in extraction of natural resources is shown by British Gas’ development along the coast of Tanzania, which is expected to be as large as its extraction along the coast of Qatar.

Analysts say the rate of return on foreign investment in Africa is higher than in any other developing region. Over the last decade, six of the world’s 10 fastest-growing countries were African. In eight of the last 10 years, Africa’s lion states have grown faster than the Asian tigers. The fastest-growing economy in the world in 2011 (at 13%) was Ghana. 

As a result, Africa now has the fastest-growing middle class in the world. Some 313 million people, 34% of Africa’s population, spend USD 2.20 a day, a 100% rise in less than 20 years, according to the African Development Bank. 

The bank’s definition of middle class in Africa is people who spend the equivalent of USD 2 to USD 20 a day — an assessment based on the cost of living for Africa’s near one billion people. It is acknowledged that many living on USD 2 to USD 4 a day could easily slip back into poverty. But even when you take these people out of the equation, the bank puts the stable middle class at 123 million, 13% of the population. By 2060, says the bank, the number of middle-class Africans will grow to 1.1 billion (42% of the predicted population). 

It is, as Soros points out, the world’s fastest-growing middle class. 

By 2060, Africans living below the poverty line will be in the minority (33%). The bank describes the trajectory as ‘unstoppable’. As an indicator of recent trends, The Economist magazine, which in 2000 ran a cover story headlined ‘The hopeless continent’ recently U-turned with an article headed ‘The hopeful continent’. 

Investors cannot ignore revolutions in North Africa, and famines in east and west Africa, but the underlying mantra of ‘growth, growth, growth’ is taking hold. The International Monetary Fund (IMF) expects Africa to grow by 6% in 2012, following another 6% growth in 2011, roughly the same as in Asia and in stark contrast to the Eurozone. 

Foreign direct investment projects grew by 27% in 2011, pushing Africa’s share of the world’s investment to almost a quarter. 

Significantly, the Africa Attractiveness Survey by one of the Big Four accountancy networks points to a ‘stark contrast’ between those investors who have already invested in Africa and those who have not. The latter are concerned about corruption and political instability; they view it as ‘by far the least attractive investment destination in the world’. But for those already investing in the continent, their experience is ‘a story of progress, growth, a story of political and economic vibrancy’. 

For example, Zambia enjoyed a 93% rise in investments in 2011 — ‘a result of a well-managed economy and a peaceful handover of power’.

One of the most striking examples of growth is in Nigeria, hit by terrorist attacks but where GDP grew five-fold between 2000 and 2011, according to the International Monetary Fund (IMF). A survey by global Initial Public Offering specialists Renaissance Capital reports that nearly half of Nigeria’s middle class (defined as people with an average monthly income of USD 500–600) are planning to buy fridges, freezers and other white goods, ‘suggesting a consumer boom is under way’. 

Africa’s fast-growing urban populations are benefitting from a commodities boom and a 10-fold rise in foreign investment in the past decade, notably from China. Over the same period, Africa’s productivity has grown by nearly 3% a year, compared with 2.3% in the US. Governance is improving (the number of democracies in sub-Saharan Africa leapt from three in 1989 to 23 in 2008); dictatorships and wars are declining (major conflicts have declined from 12 in the mid-1990s to just four today); and mobile phone technology is fast becoming as much an African symbol as the baobab tree. 

A 2011 poll found that mobile phones are owned by 71% of adults in Nigeria; 62% in Botswana and more than half the populations of Ghana and Kenya. The continent is the world’s fastest-growing mobile phone market, according to the industry group Groupe Speciale  Mobile Association. Africa’s 600 million users make the continent the second biggest user of mobile phones globally by continent, behind Asia. Subscriber levels have grown by almost 20% for each of the past five years; subscribers are expected to total 735 million by 2013. 

Around one-tenth of Africa’s land mass is covered by mobile-internet services — a higher proportion pro rata area than in India. Mobile development has enabled Africans to ‘leapfrog’ poor landline infrastructure, which has been a brake on progress. Many Africans get their first internet experience on a mobile rather than a desktop computer, using services that revolutionise commerce, farming and healthcare. Almost 18 million Kenyans use their mobiles as a bank account to deposit or transfer money and pay their accounts. 

In places such as Rwanda’s capital Kigali — with lasting memories of its 1994 genocide — technology start-up companies are flourishing. Similar start-ups flourish in Kenya, Nigeria and South Africa. By comparison with mobile phones, internet communications are relatively low at 120 million users, but growth between 2000 and 2011 was 2,527%, compared with a world average of 480%. Twenty-seven per cent of Africa internet users have Facebook profiles, compared with 18% of users in Asia. 

Shopping malls, with wireless-equipped coffee shops, show the rise of the African consumer: the Accra Mall in Accra, Ghana; The Palms in Lagos, Nigeria; Westgate in Nairobi, Kenya. Trade in cars and motorcycles are prolific (car ownership in Ghana, for example, has risen by 81% in the past five years). 

Along with the rise of the middle classes are coming ‘middle class values’ more recognised outside the continent: families are smaller; they are owning their own homes; and heads of households have salaried jobs or run their own small businesses. 

Thanks to debt relief in Africa, and a borrowing boom in Europe, many European countries are more indebted than African nations. Oil-rich Angola is lending cash to its former colonial master Portugal. New African multi-millionaires are being minted at such a rate that Forbes, the Bible of global business elite, has published its inaugural ’40 richest Africans’ list. At the top is Aliko Dangote, a sugar, flour and cement magnate based in Lagos, worth USD 13.8 billion. 

As economies and middle classes grow, so does investment and so do businesses — some so much that they are buying up global rivals. South African Breweries has bought the US’ Miller to become SAB Miller, the world’s second-largest brewer. The US’ retail giant Walmart, the world’s biggest retailer, has invested USD 2.4 billion acquiring a majority stake in South African grocery retailer Massmart so it can springboard across Africa, starting in Nigeria. From the UK, London-based Lonrho is investing USD 300 million in the continent, setting up a new regional airline and opening 50 mass market hotels. Live Aid co-founder Bob Geldof, who in the 1980s urged the world to donate to save Africa, has established his own fund to make investments in agri-businesses, financial services and telecommunications. 

One way investors are taking a ‘safety net’ leap into Africa is through the Indian Ocean island of Mauritius. Multinational corporations, investment funds and other international investors — attracted by above average returns and high growth rates — are increasingly favouring the Mauritius Global Business Sector as a platform of choice to structure their investments into African countries. 

Mauritius has signed Double Tax Treaties with 11 African countries (South Africa, Botswana, Lesotho, Mozambique, Namibia, Rwanda, Senegal, Swaziland, Uganda, Zimbabwe, Tunisia) and treaties with four other countries (Malawi, Ghana, Kenya, Nigeria) are awaiting ratification.

“By choosing the Mauritius route into Africa, investors can avail of the treaty benefits and achieve significant tax savings, mainly in the form of reduced withholding tax on dividend distributions and exemption from capital gains,” says Nirmal Heeralall, of UHY’s member firm on Mauritius, UHY Heeralall. 

Mauritius has also signed Investment Promotion and Protection Agreements with 15 African countries which, typically, offer certain guarantees to investors, such as free repatriation of investment capital and returns, guarantee against expropriation and dispute settlement arrangements. 

“Its proximity to Africa and membership of the African Union; Southern African Development Community; Common Market for Eastern and Southern Africa; and Indian Ocean Rim – Association Regional Cooperation are among the other reasons why investors choose Mauritius as their preferred investment route into Africa,” says Heeralall. 

But UHY also has member firms in northern Africa and sub-Saharan Africa in stable jurisdictions favoured by investors for direct investment. Especially in the north, business practices and investment incentives are more readily conducive to Western investors. 

In Tunisia, for example, the government has adopted market mechanisms aimed at encouraging free trade. Prices have been liberalised, taxes have been reduced, the national currency (the dinar) has been made convertible, and the state has disengaged from competitive activities to the benefit of the private sector. 

The government plans to continue with its programme of structural reform, including fiscal consolidation and a reduction in public debt as a proportion of GDP. 

“As a result, fiscal incentives to increase private-sector investment are being implemented and a liberalised investment code, the Investment Incentives Code, has been drawn up to encourage foreign investment,” says Raoudha Ben Abdelkrim, of UHY’s firm in Tunisia, UHY CNBA. 

The code is the law and governs both national and foreign investment – except in mining, energy, local trade and finance, which are governed by specific regulations. Some businesses become eligible for incentives offered under the code by self-declaration; others require prior authorisation. 

Incentives include: 

  • Tax relief on reinvested profits and income up to 35% of the income or profits subject to taxCustoms duties exemption for capital goods that have no locally-made counterparts
  • VAT limited to 10% on capital goods imports
  • Possibility to choose a reducing balance method of depreciation for production material and equipment where its useful life exceeds seven years. 

The government aims to cut unemployment and lift living standards to Organisation for Economic Co-operation and Development (OECD) levels by increasing foreign and local investment, production and exports, while keeping inflation and the fiscal current-account deficits under control.

Priorities include addressing financial sector weaknesses, which act as a drag on growth; fiscal consolidation; paying down external debt; upgrading industrial infrastructure; and enhancing labour market flexibility.

“Oil exploration plans are also expected to stimulate foreign direct investment,” says Ben Abdelkrim. “Tunisia and Malta are discussing the commercial exploitation of the continental shelf between their countries. Moreover, recently Tunisia has attracted unprecedented interest from the monarchies of the Gulf. Their investments in services, tourism and banking to date have more than doubled in recent years. Arab capital accounts for more than 20% of all foreign investment.” 

Foreign investment could also be encouraged by the government eliminating the need for prior authorisation for the acquisition of small and medium-sized companies, and for the purchase and rent of land and premises in industrial and tourist areas. 

The government — with its official target of 6% economic growth per annum — is expected by economists to favour boosting investment in manufacturing; promoting high-value knowledge-based industries; modernising agriculture and infrastructure; strengthening the financial sector; and restructuring education. 

Africa may still be the poorest continent in the world, but Africans have had enough of being the world’s victims. Their time has come and their timing is sound — as debt-laden economies of the West face their worst crises since the 1930s. It’s small wonder that the rate of return on foreign investment in Africa is higher than in any other developing region, according to McKinsey. No wonder, as Soros says, investors with foresight see Africa as ‘one of the few bright spots’ on the economic horizon. 

Contact: Nirmal Heeralall 
Email: nirmal.heeralall@uhyheeralall.com 

Contact: Raoudha Ben Abdelkrim 
Email: cnba@tunet.tn 

 

With power comes responsibility

Beijing is making its mark in Latin America.

In 2000, China was the seventh-largest export market for Latin America and accounted for less than 2% of the region’s exports. Today, China accounts for 10% of Latin America’s exports and is the leading export destination for Brazil and Chile. 

But that’s not the whole picture. The United States and Europe remain Latin America’s most important trading partners (as shown in the barchart below). And, China’s rise, albeit significant, should be put in the context of a broader shift towards a world in which emerging markets have greater economic weight.

Moreover, the US remains a key provider of remittances to Latin America — accounting for 75% of the USD 60 billion the region received in 2008 — and so is a critical source of foreign exchange for many countries in the region.

Closer examination also reveals that there is a marked difference between China’s importance as an export market for the Latin America region as a whole – predominantly focused on natural resources – and as an export market for Mexico, whose export products often compete with China’s output.
 

But, overall, there is no question that investment into Latin America from China is increasing at a record pace. China is now the third-largest external investor in the region, behind the US and the Netherlands. 

According to the United Nations Economic Commission for Latin America, China’s foreign direct investment in Latin America reached USD 15.3 billion in 2010 and USD 22.7 billion in 2011, up from much lower levels in each of the previous nine years.

 

Global market implications

So what are the global market implications of China’s emergence in Latin America? Significant as it is for the region’s economic prospects, China’s emergence is only one aspect of the way in which emerging economies are rapidly reshaping the global economy.

Already, in purchasing power parity terms, four of the seven largest global economies — Brazil, Russia, India and China — are ‘developing’ countries. According to projections by the US’ Carnegie Endowment for International Peace (in its Juggernaut report on how emerging economies are reshaping globalisation), Mexico will join the world’s top seven economies by 2030 and Indonesia by 2050. 

By then, the US will be the only currently advanced country to rank among the world’s seven largest economies. 

At the same time, China will become the centre of world trade, representing by far the largest trading partner for most countries. Its share of world trade will reach 24% by 2050, up from about 10% today.
 

Opportunities for Latin America 

The rise of emerging economies, including China, will create major opportunities for Latin American countries. Today, about 40 per cent of Latin America’s exports go to developing countries, including China; this figure will surge as developing countries’ share of world exports more than double from 30% in 2006 to 69% in 2050. 

Moreover, the rise of Brazil and Mexico, and their burgeoning middle classes, will be a boon for other Latin American economies. Brazil already accounts for a quarter of intraregional exports. 

The emergence of the developing world and weaknesses in advanced economies — income inequality and political gridlock in the US, the debt crisis in the Eurozone, and the fiscal and demographic crisis in Japan — will lead to a very different economic order, one in which huge new markets and new sources of competition will arise, and one in which power and influence are more widely distributed. 

For the first time, the world’s largest and most powerful economies will be relatively poorer nations.
 

Challenges for Latin America 

Economists from Carnegie’s International Economics Program argue that China’s rise, and the broader shift of the world’s economic centre of gravity, raise at least three economic policy issues for Latin America to address: what they call ‘comparative advantage; priorities for economic diplomacy; and the region’s role in the global order.

Contrary to popular impression, the economists assert that Latin America’s commodity exporters cannot be sure that the rise of China, and other developing countries, will sustain a commodity price boom in the longer term, so diversification of their economies remains a challenge.

For nearly all commodities (petroleum could be a partial exception), increased demand may well be eventually matched by increased investments in supply and technological innovation that reduces production costs and develops new substitutes — as has happened historically. 

As business conditions in Russia, Indonesia, Africa and other natural resource exporters improve, so too will their capacity to export commodities. 

Moreover, demand for commodities in Latin America will eventually be held back by a natural shift to services and goods as incomes rise, as well as by innovations which reduce the wastage and intensity of commodity use. 

Latin American resource-based economies may sooner or later need to strengthen their capacity to produce goods and services, the demand for which will soar as the middle class burgeons domestically and in other emerging markets. 

At present, nearly 90% of Latin America’s exports to China are in mining and agriculture. Although the region’s terms of trade have improved, on average, by nearly 4% annually between 2002 and 2008, compared to 0.5% a year between 1995 and 2001, there is no guarantee that this recent favourable trend will persist. 

Given structural changes in global demand and supply implied by the rise of the emerging powers, and uncertainties inherent in predicting commodity prices, Latin America’s development strategy should, say the economists, encompass a number of economic strategies — such as investing in education, strengthening governance, improving the business climate, and enhancing the capacity to innovate.
 

Economic diplomacy

Although the relative size of the US economy is expected to decline over coming decades, the US is projected to remain an important destination for Latin America’s exports, even in 2050. Similarly, although the importance of individual European economies to Latin America will decline over time, the European Union as a trading bloc is likely to remain among the region’s major trading partners. 

So, while Latin American countries will need to reorient their economic diplomacy towards emerging powers — including fostering trade and investment agreements — relationships with Europe and the US will remain critical.
 

Global responsibility 

Latin American countries are becoming more influential on the world stage. Brazil and Mexico are already playing a prominent role in the G20, the new premier forum for global economic decision-making, of which Argentina is also a member. But as their economic power continues to grow, say the economists, they will need to assume greater responsibility in shaping and contributing to international economic integrity. 

Latin America’s countries need to define their own vision of how the global trading system, financial regulation, migration policies, development assistance, and efforts to mitigate climate change should evolve.

With power comes responsibility. 

UHY has offices in China and in Latin America, including in Argentina, Brazil, Chile, Colombia, Ecuador, Mexico and Peru. For details: 

Contact: Dominique Maeremans 
Email: d.maeremans@uhy.com

 

Tax Treaties – How they work for effective tax planning

The first years of the 21st century have seen renewed interest and developments of a trusted 19th century vehicle for tax planning – the double taxation treaty.

Whether it will be adaptable to confront business models such as web-based commerce, and have the ability to do business without relying on traditional bricks-and-mortar, are still open questions. But, meanwhile, tax treaties remain useful tools for reducing the overall tax bite as companies, and the employees who work for them, continue to cross borders both in real and virtual terms.

Download the International Tax Treaties White Paper as a PDF