Marcus Stelloh

Marcus Stelloh

  • Transfer Pricing Partner 
  • 20 years experience

"I will bring proactive international tax and transfer pricing insight to every stage of the engagement, helping Sanlam and Santam navigate evolving global requirements with confidence. By combining deep technical expertise with a practical understanding of your business, I will identify risks early, provide clear guidance, and support sustainable value across your international operations. "

Marcus is a Partner in the Transfer Pricing division of BDO South Africa, with over 20 years experience advising multinational groups across South Africa and Africa. He specialises in operating model design, intercompany pricing, and transfer pricing strategies that align commercial objectives with regulatory requirements. Recognised for his structured and evidence-based approach, Marcus designs practical, defensible transfer pricing policies grounded in a deep understanding of business value creation. His experience spans tangible goods, services, intangibles, and financial transactions, supported by robust value chain analyses, method selection, and documentation strategies. He works closely with finance, legal, and operational teams to translate business strategy into effective transfer pricing frameworks, agreements, and compliance documentation. His expertise includes the development of master and local files that are data-driven, consistent, and audit-ready. 

Marcus brings significant experience in transfer pricing audits, controversy management, and dispute resolution. He prepares detailed comparability and financial analyses, develops scenario-based models, and formulates technical positions that withstand regulatory scrutiny. He has successfully engaged with tax authorities across Africa on audit management, negotiations, and dispute resolution matters. Having worked in both South Africa and Australia, Marcus offers a global perspective and extensive experience supporting multinational groups, including those with European headquarters. Fluent in English and German, he has advised clients across automotive, FMCG, mining, oil and gas, financial services, IT, manufacturing, distribution, telecommunications, and shared services sectors. Marcus is an active contributor to the profession, serving on the SAICA Transfer Pricing & International Tax Sub-Committee and the BDO Global Transfer Pricing Advisory Committee. He is also a regular speaker at leading industry forums, including TP Minds, SAIT Transfer Pricing Summits, and BDO global events.

Largest Financial Services clients serviced:

  • Allan Gray
  • M&G
  • Investec
  • Industrial Development Corporation
  • Citi Group
  • Finbond

Qualifications and professional affiliations 

  • Chartered Tax Adviser (SAIT)
  • Member of SAICA Transfer Pricing & International Tax Sub-Committee
  • BDO Global TP Markets and Growth Leader