Marcus Stelloh

Head of Transfer Pricing

Transfer Pricing Services



Marcus has close to 15 years’ experience in transfer pricing, cross-border structuring and international tax gained at BDO South Africa and previously PwC, Deloitte Australia, EY, Grant Thornton and the South African Revenue Service (SARS).

His extensive knowledge of transfer pricing includes, but is not limited to the following:

  • Transfer pricing planning: analysing and resolving international and local transfer pricing issues faced by multinational enterprises within South Africa, Australia and Africa.
  • Transfer pricing compliance: putting in place appropriate documentation to support client transfer pricing policy documents within South Africa, Australia and Africa.
  • Transfer pricing defence strategies and litigation support: drafting comparability and detailed financial analyses which involves building financial models that allow for various scenario analyses
  • Transfer pricing negotiations with SARS

Marcus’s experience in specific sectors includes mining (coal, base metals, PGMs and gold), oil and gas (upstream, downstream and seismic operations), financial services (asset management and reinsurance), information technology, manufacturing, distribution, telecommunications, services, shared services and cooperatives.


  • BCom
  • PG Dip. Tax (South African Tax)
  • PG Dip. Tax (Australian Tax)
  • MCom (Transfer Pricing)
  • Bachelor of Commerce (Rhodes University)
  • Postgraduate Diploma in Tax (Rhodes University)
  • Postgraduate Diploma in Australian business and investment tax (University of Sydney)
  • Masters in Commerce


He is a member of BDO International transfer pricing centre of excellence, is a Registered Master Tax Practitioner with SA Institute of Tax Practitioners (SAIT) as well as a o SAICA Transfer Pricing and International Tax Sub-committee member