Crowe Horwath TM African Footprint Technical Newsletter of the Crowe Horwath International African firms Issue 8 - July 2013 Djibouti Inside This Issue: The Republic of Djibouti is a country located in the Horn of Africa, It is bordered by Eritrea in the north, Ethiopia in the west and south, and Somalia in the southeast. Djibouti 1 The on-going Voluntary Disclosure Programme (VDP) in South Africa 2 The population of Djibouti 2013 is estimated at 792,198. Owing to a number of ethnic groups in the country, the culture of Djibouti is very rich and assorted. Arabs, French, Somalis, and other minority groups make up the ethnicity of Djibouti. The people of Djibouti are very hospitable, kind, and generous. The main indigenous languages are Afar and Issa-Somali, both of which belong to the Cushitic language group. The official national languages are French, which is used in education and administration, and Arabic, which is spoken by Yemeni and other Arab immigrants. Islam is the national religion and is practiced by the majority of the population. Treatment of Withholding Tax and Value Added Tax on Reimbursements, Disbursements and Recharges in Kenya 3 The Djibouti location is its main economic asset which gives the African country a strategic advantage. Djibouti lies at the crossroads of one of the busiest shipping routes in the world, linking Europe, the Far East, the Horn of Africa and the Persian Gulf. The Port of Djibouti serves as a key refueling and transhipment centre, and is the principal maritime port for imports to and exports from neighboring Ethiopia. The location has also helped the country to become a renowned naval port in the world. The country hosts the only US military base in Africa and also a small French base. The country's economy is based on its strategic geographic location at the mouth of the Red Sea and its status as a free trade zone in the Horn of Africa. Its main economic activities are the Port of Djibouti, the banking sector, the airport, and the operation of the Addis Ababa-Djibouti railroad. Foreign direct investments are welcomed by the Government of Djibouti and tax incentives are given. Audit Tax Advisory Budget - East African Community States Prioritise Growth 4 Purchase of Real Estate in South Africa by non-residents - a brief high level overview 5 Africa and Middle-East meeting in Dubai 7 Upcoming Training 7 The Concepts of Thin Capitalization and Deemed Interest: The Case of Kenya 8 Feedback from our Readers! Should you wish a specific topic to be covered in our next issue, please let us know by emailing your request to our editor kent.karro@crowehorwath.co.za 1 Crowe Horwath TM The Djiboutian Franc is the currency of Djibouti. Rather than function as a Central Bank, the Banque Centrale de Djibouti (BCD) has followed a Currency Board FX regime for over 30 years. The Djibouti Franc is fully backed by foreign exchange reserves and the country controls inflation by pegging the currency to the US dollar. Djibouti has no foreign exchange restrictions or restrictions on the transfer of funds or cash. Crowe Horwath EA Opens New Office in Djibouti Crowe Horwath Djibouti SARL provides audit, tax, advisory and legal services and is headed by Otolo Coutts Akolo, the CEO of its parent company Crowe Horwath EA in Kenya, and by Melanie Guérinot, a French jurist residing in Djibouti. Crowe Horwath Djibouti was founded in May 2012 to create a firm of professionals, with a strong international brand, that provides professional quality services. The Djibouti office forms part of the fast developing Crowe Horwath network across Africa and will play a key role in providing professional services to other francophone countries. This has been done to facilitate the development of multi-disciplinary and multilingual teams that can provide professional services to any parts of the region and Africa at large. The office offers services to investors, and can provide expert advice on local taxes, customs and systems, as well as introductions to influential local contacts. Mr Coutts Otolo Crowe Horwath Djibouti Sarl Djibouti The on-going Voluntary Disclosure Programme (VDP) in South Africa Section 226 of the newly introduced Tax Administration Act (TAA) in South Africa allows for the application by taxpayers for relief under what has become known as the “on-going VDP programme”. Under the provisions of the TAA, the South African Revenue Service (SARS) must permit a valid application and apply the provisions of Part B of the TAA – “Voluntary Disclosure Programme” so long as the qualifying criteria for a valid application exist i.e. a person may apply, whether in a personal, representative, withholding or other capacity, for voluntary disclosure relief, unless that person is aware of (a) a pending audit or investigation into the affairs of the person seeking relief; or (b) an audit or investigation that has commenced, but has not yet been concluded. The requirements for a valid voluntary disclosure are that the disclosure must (a) be voluntary; (b) involve a 'default' which has not previously been disclosed by the applicant or a person; (c) be full and complete in all material respects; (d) involve the potential imposition of an understatement penalty in respect of the 'default'; (e) not result in a refund due by SARS; and (f) be made in the prescribed form and manner. We are finding that many taxpayers are unaware of the existence of the above provisions and hence do not afford themselves the opportunity to minimise the penalties (note: not all penalties are covered) and/or interest which SARS may seek to impose where they become aware that they have transgressed the law or simply wish to regularise their incorrect application of the law. Should you be aware of any provisions of the South Africa Tax Acts which you may not have applied correctly we would be happy to assist you in seeking VDP relief. Bibliography: Section 226 and 227 of the Tax Administration Act, 2011 Mr Michael J McKinon Horwath Tax Consulting (Gauteng) (Pty) Ltd Gauteng, South Africa 2 Crowe Horwath TM Treatment of Withholding Tax (WHT) and Value Added Tax (VAT) on Reimbursements, Disbursements and Recharges in Kenya Introduction Withholding tax (WHT) can be defined as a tax that is deducted at source on the provision of certain services and incomes. The recipient of the services is expected to deduct tax at the appropriate rate and remit the same to the government on behalf of the provider of these services who in turn will claim the same at the year end when doing his/her self-assessment. In Kenya, the deduction of WHT is guided by the Income Tax Act Cap 470. (Laws of Kenya) and applies to contractual, management and professional fees. VAT on the other hand is covered by the VAT Act, Cap 476. (Laws of Kenya) and is defined as a tax charged where there is value addition on a product or a service. Typically, it can be said to be a tax charged on the selling price. The above terms (reimbursement, recharge and disbursement) are assumed by many to be interchangeable and to have the same meaning and almost given the same treatment for tax purposes. This is incorrect. What then do these three simple words mean and what is their tax treatment as far as WHT and VAT are concerned? Reimbursement To reimburse is to pay back or compensate (another party) for money spent or losses incurred (Online Dictionary).The costs are incurred and received by the customer. This therefore implies that the person being reimbursed acted on behalf of the other person. These costs attract neither WHT nor VAT if well supported by way of invoices or payment receipts. It should however be noted that such reimbursement should not be claimed by way of invoice as it will be assumed that they incorporate a profit margin and thus attract WHT and VAT. Examples include: ? Amounts paid to a supplier on a customer's behalf and who acted as an agent of that customer ? A customer received, used or had the benefit of the goods or services you paid for on their behalf ? It was a customer's responsibility to pay for the goods or services, not yours ? A customer gave you permission to make a payment on his behalf ? You pass on the exact amount of each cost to your customer Note: Reimbursements are also common in employment income computations. In this case, expenses incurred by an employee wholly, exclusively and necessary in the provision of services to the employer shall be treated as exempt “benefits” if they were paid back by the employer. However, private expenses incurred are treated as taxable benefits and taxed at the relevant scale rates. 1 Recharge Just like a reimbursement, a recharge refers to a scenario where one acts as an agent of another person but at an extra fee. i.e. a person incurs expenditure on behalf of another person then invoices that other person for those costs and adds a transaction fee. Such invoices will attract both VAT and WHT e.g. where an entity pays an expense on behalf of another, say rent, and later on invoices that other company for the cost incurred on its behalf including a handling fee. 3 5 Crowe Horwath 2 TM Disbursement This can be defined as incidental costs incurred in the course of providing a service. At this point one thing to note is that these incidental costs are incurred by the provider of the service and not the customer. Examples include: ? An airline ticket that you buy to visit a client or to travel to a job. If you recharge the cost to your client you must charge VAT because the flight was for you, not for the client. ? Postage costs you incur when you send letters to your customers. These are normal business costs and you must add VAT if you recharge them. Unlike a recharge, whether a disbursement qualifies for WHT or VAT depends on the nature of the service. This implies that if a service is exempted from tax, the disbursements are also exempted and the reverse is true. This same concept also applies on imported services which give rise to reverse VAT which works on the principle of subrogation, i.e. the recipient of the services is required by law to leave his position and take the position of the supplier of the services and to do so as though the supplier was a resident tax registered supplier. The importer is expected to declare the imported services and pay the VAT on these services using special forms called VAT 7 and VAT 28. Once the VAT has been declared and paid, the recipient of the services is allowed to include the reverse VAT as part of his input tax (using Form VAT 3) and deduct the amount in accordance with his VAT status. Conclusion For tax planning purposes in Kenya, it is better for a person to be in a reimbursement position than in a recharge or disbursement position. However, most professionals treat disbursements as reimbursements on the face of their invoices / fee notes to a client and omit charging VAT and WHT. Such omissions attract penalties from the revenue authority which can be avoided altogether by proper tax planning. Justus Masabe Horwath Erastus & Company Nairobi, Kenya Budget - East African Community States Prioritise Growth The East African Community (EAC) partner states recently presented their national Budgets with a focus on the socioeconomic transformation in the next fiscal year of 2013/2014. There was an increase by partner states in their budget allocations compared to 2012/2013 Budgets, putting emphasis on infrastructure and agriculture, which is an indication of fast-tracking economic growth, while promoting inclusion and sustainability. Rwanda The Rwanda government has increased the national budget from over Rwf1.5 trillion in 2012/2013 fiscal year to Rwf1.6 trillion in 2013/2014. The focus is on transforming infrastructure and agriculture sectors. Economic transformation has been allocated Rwf459 billion which makes it 28 percent of the total budget, rural development Rwf164 billion (10 percent) of the total budget, productivity and youth employment Rwf163 billion (10 percent). "The remaining Rwf41billion which adds up to two percent has been allocated to accountable governance," according to the budget. Presenting the budget, Amb. Claver Gatete, Rwanda's Minister of Finance and Economic Planning, said in the last decade, Rwanda experienced an exciting period of economic growth and socio-economic progress. 4 Crowe Horwath TM Uganda Tanzania The Ugandan government has budgeted Shs12 trillion that combines spending cuts to various sectors of the economy with tax increments. The country is seeking ways to close the deficit left by aid cuts resulting from the theft of donor funds in the public administration. Tanzania, the largest EAC country unveiled TZSh18.2 trillion to cover several social and economic sectors as the country puts much emphasis on infrastructure development and upholding fiscal measures. The budget is 18 percent higher than the amount spent in the 2012/2013 Budget. The Tanzanian Finance Minister, Dr William Mgimwa, said the country has managed to contain inflation and the emphasis will be put on anti-inflationary measures while promoting an investment friendly environment. The 2012/2013 national budget for Uganda was at Shs10.25 trillion meaning that the country has increased over the 2013/2014 financial year by more than Shs2 trillion. "The financial year 2013/14 budget, like the one last year, will continue to focus on translating the Government's strategic priorities into practice over the next year," Maria Kiwanuka, Uganda's Finance Minister said while presenting the budget in Kampala. Kenya Kenya has the biggest Budget compared to other EAC member states. The Kenya's Cabinet Secretary for the National Treasury, Henry Rotich presented a Sh1.6 trillion 2013/2014 budget despite the fact the country has a total debt of Sh1.8 trillion, with Sh800 billion borrowed in domestic debt and Sh1 trillion as external debt. Kenya's Budget increased from Sh1.459 trillion in 2012/2013 to Sh1.6 trillion in the next financial year. The country's budget has been allocated to various sectors like health (Sh34.7 billion), transport (Sh125 billion), energy (Shs78.5 billion), ICT (Shs9.5 billion), and education and technology (Sh130 billion) among others. Burundi Burundi's budget is small compared to the other member states. The government has presented BIF1.9 trillion for the 2013/2014 financial year that will be channelled towards the economic recovery following the several adverse economic shocks the country suffered last year. At relative peace since rebels joined the government in 2009, Burundi now focuses on transforming the economy and self-financing its national budget by 2025. The 2013/14 budget predicts the economy, heavily dependent on coffee exports, will grow by 6.6 percent, up from an estimated 4.7 percent in 2012. Nevertheless the EAC partner states have one thing in common - achieving economic structural transformation while lifting citizens out of poverty. Michelè De Witt Horwath HTL Cape Town, South Africa Purchase of Real Estate in South Africa by non-residents - a brief high level overview Many non-resident private individuals (and entities) have acquired real estate in South Africa, as holiday homes or as investments and sometimes with both purposes in mind. There are currently no restrictions on the purchase of real estate by non-residents but there are important income tax and exchange control considerations which should be borne in mind. Income Tax A non-resident private individual or entity will need to register as a taxpayer in South Africa to ensure that net rental income is subjected to South African Income Tax and that a capital gain realised on disposal will also be declared for tax purposes. A non-resident entity may also need to register as an external company in terms of our company law requirements. A non-resident individual or entity will only be liable to South African Income Tax on income and capital gains derived from a South African source. A percentage of capital gains (33.3% in the case of a private individual and 66.6% in the case of entities or trusts) is included as normal taxable income and subject to our standard income tax rates. There is no separate Capital Gains Tax. 5 Crowe Horwath TM When a non-resident sells South African real estate, there is a withholding tax of 5% of the gross selling price (in the case of a private individual) which must be paid over to the South African Revenue Service (SARS) as payment on account of the tax as finally assessed. The rate is 7.5% in the case of a company seller and 10% in the case of a trust. If the tax on the computed capital gain is likely to be less than such withholding tax, a directive can be applied for from SARS so that a reduced amount of tax needs to be withheld. In all cases, the real estate owner will need to file with SARS an annual tax return for each period of 12 months ending on the last day of February in each year. A company may request a different year end. Income tax on an annual basis will be payable on the gross rental income less the expenses incurred to produce such income (e.g. municipal rates, repairs, maintenance, electricity, water, rent collection commission and similar expenses which may be borne by the owner). Income tax would also be payable on a capital gain arising on the actual or deemed disposal of the real estate. A deemed disposal arises on the date of death of the non-resident individual holding real estate in South Africa. In certain cases there may be a double tax treaty between South Africa and the home country and the terms thereof may override the local tax rules. If, subsequent to the purchase of the real estate, the nonresident owner incurred costs on capital improvements to the property, records of such expenditure (and the source of the funds) must be carefully retained. As such costs may be taken into account in the computation of the taxable capital gain, the absence of documentary evidence and proof could result in SARS not allowing any deduction for such costs. Similarly, records need to be retained of all costs relating to both the acquisition of the real estate (e.g. transfer duty, VAT, transfer costs, bond registration costs, other lawyer fees, etc) as well as those relating to a subsequent sale (e.g. selling commission, electrical and other certificates, rates clearance certificates, lawyer fees, etc). So as to ensure that there is no obstacle to repatriating funds, it is essential that record of the funds coming into South Africa must be retained and the use of such funds must be able to be tracked. Accordingly, if funds are remitted from outside South Africa to a local lawyer to pay for real estate, it is essential that proof of the funds transfer is collated and retained by the owner as the lawyer will probably destroy his records after 5 years. It is important therefore to request from the lawyer written confirmation that he received such funds from offshore direct into his trust bank account and an accounting as to how such funds were disbursed. Copies of the real estate purchase agreement and subsequent sale agreement and related statements from the lawyers must also be carefully retained. If the funds were to be used to form or acquire a local company for it to acquire the real estate, it is also critical to place on record with SARB, the fact that the local company is borrowing funds from a non-resident lender and the terms of such loan. It would be incorrect (and cause major delays later) if it was stated that the funds came into South Africa to purchase real estate when, in fact, a local company purchased the real estate using funds borrowed from the non-resident. Conclusion Non-residents acquiring real estate in South Africa need to consult local professionals to handle their tax and exchange control needs and requirements. The lawyer handling the transaction is normally acting for the seller and may (or may not) be equipped to also handle these aspects for the purchaser. We are fully qualified to handle all these matters and would be happy to offer advice to any potential or existing real estate owners. Kent Karro Horwath Zeller Karro Cape Town, South Africa Exchange Control Funds introduced by non-residents into South Africa may be repatriated in full together with any after-tax income and gains made during the holding or disposal thereof. Despite this, there are administrative controls in that the movement of funds has to be reported to the relevant department of the South African Reserve Bank (SARB) and this is done via the local South African commercial banks. 6 Crowe Horwath TM Africa and Middle-East meeting in Dubai Following the successful Africa meeting which took place in Arusha, Tanzania, last year the African firms decided to organise a second event and invited their colleagues from the Middle-East to join them. This event took place in Dubai on 19 and 20 February and was preceded by an Audit & Accounting training presented by David Chitty. 31 participants from 15 countries attended the meeting. The agenda included updates by the International Accounting & Audit Director, David Chitty and the International Tax Director, John Stewart, presentations about industries, more specifically natural resources and Islamic Banking. Discussions about the future of each region took place; Mark Watson presented an update on the Africa strategic plan - Rabea Al Muhanna and Saad Maniar were appointed to coordinate efforts for developing a coordinated approach for the Middle-East. As usual the meeting was the opportunity to get to know each other better, to facilitate networking and to build new relationships between the offices. We welcomed for the first time our new colleagues from Yemen and guests from China, India, the United Kingdom and France. Our thanks go to Horwath Mak for their support and more specifically to Dr Khalid Maniar and his wife who hosted a dinner at their residence, showing as usual a wonderful sense of hospitality. Before leaving Dubai, delegates decided that this meeting should take place again next year, this time in Africa at a location which will be decided at a later stage. Bernard Delomenie Regional Director Europe, Middle East & Africa Crowe Horwath International Upcoming Training Level 2 Valuation Training Course in Prague, Czech Republic The GCA Valuation Task Force invites you to attend our next Level 2 and Purchase Price Allocation Valuation Training Seminar. The GCA Valuation Task Force is Crowe Horwath International’s special interest group dedicated to providing valuation services to a range of situations but specifically to companies engaged in cross-border transactions. Some topics that will be covered - “Developing a Valuation Practice”, “Discount and Capitalisation Rates with stand-alone problems” and “Intangible Asset Valuation - Methodologies”. For further information, please contact Daniela Pekarkova at daniela.pekarkova@tpa-horwath.cz Date: 18 - 20 September 2013 Venue: TPA Horwath, Prague 2, Czech Republic Audit & Assurance Training in Johannesburg, South Africa The African region invites you to attend a training session to be presented by David Chitty. Some topics that will be covered - “Service Standards”, “Quality Control”, “Update on Crowe Horwath International Audit Methodology”, “Regulatory Reports” and “Fraud Risk”. A Caseware representative will also be present to deal with the practical issues relating to the implementation of Caseware. For more information, please contact Cephas Osoro at cephas.osoro@crowehorwath.co.ke Date: 14 - 15 November 2013 Venue: Horwath Leveton Boner, Johannesburg, South Africa 7 Crowe Horwath TM The Concepts of Thin Capitalization and Deemed Interest: The Case of Kenya Background The Significance of Thin Capitalization The concept of thin capitalization takes us back to the initial stages of company formation where a company's assets are financed by the owners of the company through their contributions (commonly referred to as shares) as share capital or through borrowings (Debt). On the face of it there seems to be no problem in taking either of the aforesaid approaches of financing independently or jointly but on a closer look there's exposure to tax on Equity financing compared to Debt financing as will be discussed later in this article. In Kenya, as provided in the Income Tax Act Cap 470 of the Laws of Kenya, Thin Capitalization is based on two issues; Control and the Degree of Leverage. A company is thinly capitalized where it is in the control of a nonresident person (alone or together with four or fewer other persons) and the highest amount of all loans held by the company at any time during the year of income exceeds the greater of three times the sum of the revenue reserves and the issued and paid up capital (of all classes of shares of the company). This rule does not include banks or financial institutions licensed under the Banking Act. When shareholders inject cash into a business in the form of shares (equity), they expect to earn a dividend paid out of profits whereas the lenders of cash into a business (debt) expect to earn returns (interest / dividends) on their investment. For taxation purposes, dividends are not allowable deductions but an interest expense is generally allowable as a deduction. The Act further defines control to mean the power of a person to secure, by means of the holding of shares or the possession of voting power in or in relation to that or another body corporate, or by virtue of powers conferred by the articles of association or other document regulating that or another body corporate, that the affairs of the first mentioned body corporate are conducted in accordance with the wishes of that person in relation to a company. In the case of a body corporate, unless otherwise expressly provided for by the articles of association or other instruments regulating it, control shall mean the holding of shares or voting power of twenty-five percent or more. It is this concept of disallowing part of interest costs which gives rise to a concept called “deemed interest”. Deemed interest is an amount of interest equal to the average ninety-one day Treasury Bill rate, deemed to be payable by a resident person in respect of any outstanding loan provided or secured by the nonresident, where such loans have been provided free of interest. The Kenya Income Tax Act gives the Commissioner of Income Tax powers to determine the rate to be used in calculating deemed interest in respect to a particular period. Deemed interest attracts a withholding tax of 15%. Though interest is usually treated as an allowable expense, the Kenyan Income Tax Act stipulates that the interest expense shall be disallowed if a thinly capitalized company holds loans that are greater than three times the sum of the revenue reserves and the issued and paid up share capital of all classes of shares of the company i.e. exceed the debt to equity ratio of 3:1. The intent of restricting deductible interest is to allow Companies to be financed by their non-resident shareholders using a reasonable level of debt while protecting the tax base against interest deductions from excessive amounts of foreign debt. Deemed Interest In relation to a partnership, the right to a share of more than one-half of the assets or of more than one-half of the income of the partnership. Thin Capitalization therefore essentially refers to the situation in which a company is financed through a relatively high level of debt compared to equity. (A highly geared company). A thinly capitalized entity is largely in the hands of non-resident. 8 Crowe Horwath TM Deemed Interest at a glance and computation example Assuming a prescribed rate of interest of 4% for the quarter ended 31 December 2012, Company X a resident company is thinly capitalized and has an outstanding amount of kshs. 2,000,000 as its interest free loan from its foreign based shareholders. Deemed interest shall be: 2,000,000 x 4% x 3/12 = 20,000/= Withholding tax at 15% =20,000 x 15% = 3,000/= From this illustration kshs. 20,000 is treated as a disallowed expense and taxed at 30%. The gross tax revenue to the government will be 9,000 (30% x 20,000 = 6000 and WHT = 3,000). Approaches to Thin Capitalization Underlying the rule of thin capitalization is the tax revenue objective of restricting (and hence reducing) the amount of deductible interest as a result of excess debt. Countries take different approaches to determining the amount of debt that can give rise to deductible interest payments. The following two approaches can be used: 1 The arm's length approach This approach tends to look at a company's policy or measures put in place in determining how much to borrow at the prevailing market rate (arms length). The amount of deductible interest will be calculated on the maximum amount of loans that an independent person would be willing to lend to the local company at the prevailing market rates. That amount of loan is what is used to apportion the deductible interest for tax purposes. This approach is quite tedious more so when it comes to determining the criteria that a lender uses to determine the credit worthiness of a company. 2 The ratio approach This approach is what the Kenyan Government (Kenya Revenue Authority) has adopted. Unlike the arms-length approach this approach uses the maximum amount of debt on which interest may be deducted for tax purposes and is based on a pre-determined ratio i.e. the debt to equity ratio of 3:1 earlier mentioned in this article. This implies that anything in excess of the maximum provisions of the ratio will be treated as disallowable for tax purposes. The Income Tax Act looks at debt as an amount of all loans that a company has, which also means that it covers both local and foreign debts. The Kenya Income Tax Act thus defines all loans as loans, overdrafts, ordinary trade debts, overdrawn current accounts or any other form of indebtedness for which the company is paying a financial charge, interest, discount or premium. Conclusion Interest restrictions impact on the taxable income of an entity more so if dealing with interest free loans. To avoid the effects of thin capitalization, companies may have to revise their capital structures to address these emerging issues. The Kenyan tax market is fast developing and undergoes some changes every year. Those involved in tax planning and advisory work to would-be investors in Kenya need to take this into account. Justus Masabe Horwath Erastus & Company Nairobi, Kenya 9 Crowe Horwath TM Our African Network Contact Information Algeria Mauritius Hamza & Associés Tele: +213 20 508188 Email: h.tarek@hamza-dz.com Crowe Horwath (Mur) Co Tele: +230 208 8684 Email: contactus@crowehorwath.mu Angola Morocco Horwath Angola - Auditores e Consultores, Lda Tele: +244 925 289207 Email: carlos.florencio@crowehorwath.ao Horwath Maroc Audit Tele: +212 537 77 46 70 Email: benbrahim@horwath.ma Cote d’Ivoire Nigeria Uniconseil Tele: +225 08212520 Email: soraya_toure@yahoo.fr Horwath Dafinone Tele: +234 1 545 1863 Email: duvie@dafinone.com Djibouti Reunion Crowe Horwath Djibouti Sarl Tele: +253 2135 7517 Email: coutts.otolo@crowehorwathea.co.ke Fiduciaire des Mascareignes Tele: +262 2 6290 8900 Email: a.lala@fdm.re Egypt South Africa - Cape Town Crowe Dr A M Hegazy & Co Tele: +202 376 00516 Email: mahegaz@link.net Ghana SCG Audit Tele: +233 21 251497 Email: george.katako@scg.com.gh Kenya Crowe Horwath EA Tele: +254 20 2329542 Email: coutts.otolo@crowehorwathea.co.ke Kenya Horwath Zeller Karro Tele: +27 21 481 7000 Email: contactus@crowehorwath.co.za Horwath HTL (South Africa) Tele: +27 21 527 2100 Email: capetown@horwathhtl.co.za - Johannesburg Horwath Leveton Boner Tele: +27 11 217 8000 Email: info@crowehorwath.co.za Tanzania Erastus & Co Tele: +254 20 3860513 Email: erastuscpa@kenyaweb.com Horwath Tanzania Tele: +255 22 2115251 Email: chris.msuya@crowehorwath.co.tz Madagascar Tunisia Cabinet Genevieve Rabenjamina Tele: +261 202 221121 Email: cce@moov.mg Horwath ACF Tele: +216 71 236000 Email: noureddine.benarbia@crowehorwath.com.tn Mali Zimbabwe Inter Africaine d’Audit et d’Expertise (IAE-SARL) Tele: +223 20 286675 Email: iaecpt@orangemali.net One & One Chartered Accountants Tele: +263 4 304 576 Email: onemusi@yahoo.com Crowe Horwath EA, Crowe Horwath (Mur) Co, Crowe Dr A M Hegazy & Co, Crowe Horwath Djibouti, Horwath Zeller Karro, SCG Audit, Horwath Leveton Boner, Horwath Maroc Audit, Horwath Dafinone, Hamza & Associés, Horwath Angola, Uniconseil, Cabinet Genevieve Rabenjamina, Inter Africaine d’Audit et d’Expertise (IAE-SARL), Horwath ACF, Fiduciaire des Mascareignes, Erastus & Co, Horwath Tanzania and One & One Chartered Accountants are separate and independent members or business associates of Crowe Horwath International, a Swiss verein (Crowe Horwath). Each member or business associate firm of Crowe Horwath is a separate and independent legal entity and is not responsible or liable for any acts or omissions of Crowe Horwath or any other member or business associate of Crowe Horwath and specifically disclaims any and all responsibility or liability for acts or omissions of Crowe Horwath or any other Crowe Horwath member or business associate. 10