fluid talk with
Webber Wentzel
A 3-Part Deep Dive into CFC Compliance
fluid talk is a podcast-style webinar series for senior tax professionals, hosted by fluid with Webber Wentzel.
It tackles complex CFC compliance challenges through insights, case studies, and Q&A.
Sign up once to access all three episodes.
Series Content Overview
Episode 1
Date: 23rd October 2025
Time: 09:00am-10:00am
CFC Hot Spots: The Judgment Calls That Matter
Deep dive into FBE status, financial
instrument income, inter-CFC
transactions, and de minimis
thresholds – showing how to surface
the critical data points often hidden
across multiple systems.
instrument income, inter-CFC
transactions, and de minimis
thresholds – showing how to surface
the critical data points often hidden
across multiple systems.
Deep dive into FBE status, financial instrument income, inter-CFC transactions, and de minimis thresholds – showing how to surface the critical data points often hidden across multiple systems.
Episode 2
Date: 20th November 2025
Time: 09:00am-10:00am
Building an Advisor-Ready CFC Compliance Process
How to design processes that deliver
defensible evidence, decision trails,
and audit-ready data by design
– with examples of how structured
processes and automation can
transform record-keeping.
defensible evidence, decision trails,
and audit-ready data by design
– with examples of how structured
processes and automation can
transform record-keeping.
How to design processes that deliver defensible evidence, decision trails, and audit-ready data by design – with examples of how structured processes and automation can transform record-keeping.
Episode 3 Date:
January 2026
CFC Compliance in Practice: Live Panel & Scenario Clinic
A structured, interactive discussion of
attendee challenges and execution
strategies, with case studies
illustrating how centralising data
supports faster, more reliable
compliance decisions.
attendee challenges and execution
strategies, with case studies
illustrating how centralising data
supports faster, more reliable
compliance decisions.
A structured, interactive discussion of attendee challenges and execution strategies, with case studies illustrating how centralising data supports faster, more reliable compliance decisions.
Speakers
Cor
Kraamwinkel
Partner | Tax
Webber Wentzel
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Cor is an international tax specialist with more than 15 years experience. He has experience in the application and interpretation of tax treaties, holding company regimes, withholding taxes, permanent establishments, international tax structuring for both in-bound and out-bound clients, exchange control regulatory matters and South African corporate tax. He has worked with clients across numerous industries and sectors, including agriculture, finance and banking, manufacturing, mining, entertainment, e- commerce, retail, insurance, energy and private equity houses.
Cor has a B.Com in Marketing from the University of Pretoria, an LLB and LLM (Tax) from UNISA and an H.Dip International Tax focused in International Business, Trade and Tax Law from the University of Johannesburg. His expertise has been recognised by various international research organisations including Legal 500 and International Tax Review.
Cor has a B.Com in Marketing from the University of Pretoria, an LLB and LLM (Tax) from UNISA and an H.Dip International Tax focused in International Business, Trade and Tax Law from the University of Johannesburg. His expertise has been recognised by various international research organisations including Legal 500 and International Tax Review.
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Divan
Van Der Merwe
Senior Tax Manager | Tax
Webber Wentzel
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Divan specialises in corporate and international tax advisory. His experience as a tax professional includes advising on mergers and acquisitions (M&A), group reorganisations and rationalisations as well as general corporate and international tax advisory work.
Divan has a B.Com (Honours) in Accounting Sciences and an M.Com (Tax) from the University of Pretoria. He is a registered member of the South African Institute of Chartered Accountants, CA (SA) and a registered Tax Practitioner. He is also a member of the Chartered Institute of Management Accountants (CIMA). Prior to joining Webber Wentzel, Divan was a Group Tax Director at Naspers/Prosus.
Divan has a B.Com (Honours) in Accounting Sciences and an M.Com (Tax) from the University of Pretoria. He is a registered member of the South African Institute of Chartered Accountants, CA (SA) and a registered Tax Practitioner. He is also a member of the Chartered Institute of Management Accountants (CIMA). Prior to joining Webber Wentzel, Divan was a Group Tax Director at Naspers/Prosus.
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Chris
Cochrane
Founder & CEO
fluid
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Chris Cochrane is the Founder & CEO of fluid and a leading voice in tax automation. With more than 15 years in financial technology and SaaS innovation, he has built AI-driven platforms that transform how multinationals manage Controlled Foreign Company (CFC) compliance, Country-by-Country Reporting (CbCR), and global tax data automation. His work bridges local GAAP and global reporting obligations, helping organisations cut compliance timelines, reduce advisory costs, and achieve audit-ready accuracy.
Chris holds a B.Com in Statistics from the University of Pretoria and is a member of the Golden Key International Honour Society for ranking in the top 10% of his class. Recognised for technical innovation, data engineering expertise, and strategic execution, Chris continues to shape how multinationals embed automation into tax and finance workflows to stay ahead of evolving global regulations.
Chris holds a B.Com in Statistics from the University of Pretoria and is a member of the Golden Key International Honour Society for ranking in the top 10% of his class. Recognised for technical innovation, data engineering expertise, and strategic execution, Chris continues to shape how multinationals embed automation into tax and finance workflows to stay ahead of evolving global regulations.
Chris Cochrane is the Founder & CEO of fluid and a leading voice in tax automation. With more than 15 years in financial technology and SaaS innovation, he has built AI-driven platforms that transform how multinationals manage Controlled Foreign Company (CFC) compliance, Country-by-Country Reporting (CbCR), and global tax data automation. His work bridges local GAAP and global reporting obligations, helping organisations cut compliance timelines, reduce advisory costs, and achieve audit-ready accuracy.
Chris holds a B.Com in Statistics from the University of Pretoria and is a member of the Golden Key International Honour Society for ranking in the top 10% of his class. Recognised for technical innovation, data engineering expertise, and strategic execution, Chris continues to shape how multinationals embed automation into tax and finance workflows to stay ahead of evolving global regulations.
Chris holds a B.Com in Statistics from the University of Pretoria and is a member of the Golden Key International Honour Society for ranking in the top 10% of his class. Recognised for technical innovation, data engineering expertise, and strategic execution, Chris continues to shape how multinationals embed automation into tax and finance workflows to stay ahead of evolving global regulations.
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Why Attend?
Key Take-outs from the Series
Guidance from fluid and Webber Wentzel experts on blending judgment with data to defend positions with confidence
Lessons from anonymised case studies you can apply immediately
Clarity on complex exemptions and how interpretation can alter outcomes
A framework for building advisor-ready, audit-ready compliance processes
Expanded knowledge of FBE requirements applied with data-backed precision
