Naspers: Where art thou, and why?

South African Khadija Sharife has been writing on a subject dear to our hearts again, this time about media company Naspers. It begins:

"Where I come from, South Africa, Naspers is a pretty big deal, handling everything from print (production, publishing and distribution of newspapers, books and magazines), to internet (content, communication and commerce) and television. Of course, it’s not just any television, but, arguably, the finest subscription or pay-television the flat screen (or, in my house, fat screen) has to offer."

And guess what? It is big in emerging markets - but also a big user of tax havens, cutting those governments' tax revenues.

Naspers has engaged in the kind of 'aggressive' tax planning devised to strategically move such assets into low-tax regions.

Naspers intangible assets include trademarks, patents, title rights, brand names and intellectual property, as well as software, web and other forms of development. While Naspers, no doubt complies (even if creatively) with South Africa's tax rate, as the company stated, 'international tax rates vary from jurisdiction to jurisdiction.’

For the gory details, including the practice of Naspers' use of thin capitalisation techniques (used in many transfer pricing strategies), then read on.