Next Generation Partners

Tax in South Africa

Cliffe Dekker Hofmeyr

Cliffe Dekker Hofmeyr's tax team routinely advises on precedent-setting disputes and high-end corporate tax structuring for market-leading clients. Department head Emil Brincker is an 'outstanding tax expert' adept in corporate reorganisation and restructuring. Gerhard Badenhorst handles complex, high-value mandates and specialises in VAT, while Stephan Spamer focuses on structuring cross-border transactions with tax implications. Ludwig Smith advises banks and mining companies, Howmera Parak is skilled in corporate tax, international tax, and exchange control, and Petr Erasmus specialises in customs and excise. Jerome Brink is active in both contentious and non-contentious matters and Nicholas Carroll further strengthens the team’s capabilities.

Praxisleiter:

Emil Brincker


Weitere Kernanwälte:

Gerhard Badenhorst; Stephan Spamer; Ludwig Smith; Howmera Parak; Petr Erasmus; Jerome Brink; Nicholas Carroll


Referenzen

‘The CDH tax team are able to assist in extremely complexed tax matters, including advisory and dispute resolution matters. The are an extremely professional team and the service delivery is better than any other tax consulting firm in South Africa.’

‘Emil Brincker is the most well known tax professional in South Africa and well respected under clients and the tax authorities. He is able to advice on complex tax transactions from various angles as he has knowledge of a wide variety of tax matters. His turnaround time is the best in the industry and he is well known for his dispute resolution abilities.‘

‚Gerhard Badenhorst is the most experienced VAT professional in South Africa and is able to assist with complex VAT matters and has an extremely practical solution for very complex matters.’

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ENSafrica

Well-known for its 'prompt and professional service', the department at ENSafrica excels across all tax areas, including cross-border transactions, structuring, and litigation, with notable expertise in VAT, customs, and the tax elements of M&A transactions. The team, is headed up by Peter Dachs, who advises South African corporates and financial institutions on tax aspects of financing, M&A, and group reorganisations. Andries Myburgh specialises in corporate and international tax, Charles De Wet in VAT, Robert Gad in tax-efficient structuring for corporates and BBBEE shareholders, Jens Brodbeck in transfer pricing, and Kristel van Rensburg in direct tax, withholding tax, and compliance work.

Praxisleiter:

Peter Dachs


Weitere Kernanwälte:

Andries Myburgh; Charles De Wet; Robert Gad; Jens Brodbeck; Kristel van Rensburg


Referenzen

‘Kristel van Rensburg has provided great support to our company.’

‘We get very personalised service from Charles De Wet. We feel that he genuinely cares about the work and his clients. We get along great and it makes the entire process smooth and effortless.’

‘Excellent tax specialist knowledge across all areas, professional, responsive, excellent understanding of the industry and sector, well resourced.‘

Kernmandanten

Trencor Limited


South African Rugby Union


ASPASA NPC


Richards Bay Mining (Pty) Ltd


Seriti Power (Pty) Ltd


Goldman Sachs


Standard Bank


Nedbank Limited


Multichoice Limited


Sanlam


Aurous Resources


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  • Advised Trencor Limited on the unwinding of cross-border escrow arrangements and progress towards delisting and winding up including tax advice in a corporate listed environment.
  • Advised SARU on the structuring of a potential cross-border investment into SARU’s commercial interests by a foreign consortium.
  • Advised ASPASA NPC and all of its members on a pivotal dispute under the Mineral and Petroleum Resources Royalty Act, 28 of 2008; the case determined that “gross sales” for aggregate producers must be calculated at the first saleable condition (before beneficiation), aligning with sections 6(2)(b), contrary to SARS’ interpretation.

Webber Wentzel

Jointly chaired by Brian Dennehy and Cor Kraamwinkel, Webber Wentzel's tax team is praised for its 'unmatched expertise'. The team advises on a wide range of mandates, including corporate, international, and indirect tax, M&A, IPOs, employee tax and share schemes, exchange control, and tax disputes. Dennehy focuses on private equity, M&A, restructurings, derivatives, empowerment transactions, incentive schemes, and corporate tax, while Kraamwinkel advises on tax treaties, withholding taxes, cross-border structuring, exchange control, and South African corporate tax. Graham Viljoen handles local and cross-border mergers, Anne Bennett specialises in international tax, Craig Miller routinely represents blue-chip clients, and Nina Keyser focuses on tax-related dispute resolution. Shirleen Ritchie is another key name in the practice.

Praxisleiter:

Brian Dennehy; Cor Kraamwinkel


Weitere Kernanwälte:

Graham Viljoen; Anne Bennett; Craig Miller; Nina Keyser; Shirleen Ritchie


Referenzen

‚Webber Wenzel provided timely, useful and actionable advice on various transactions.‘

‘The team members were very pleasant to work with, reactive to new developments and available even when there was time pressure.’

‘The team has unmatched expertise and is simply great with clients.‘

Kernmandanten

Actis


Adenia Capital


African Rainbow Capital Financial Services


Alterra Capital


Anglo American


Astron Energy


Capitalworks


Crossfin


De Beers


Ethos | The Rohatyn Group


Infinite Partners


Little Green Beverages


Kasada Capital


Multichoice Group


Old Mutual


Pembani Remgro Infrastructure Managers


Sanlam


Sappi Limited


SunWorld International


Sun International


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  • Advised Anglo American plc and its group of companies (Anglo American Group) on the execution of a key component of its simplification plan announced on 14 May 2024, the demerger of its platinum business following the rejection of the USD49bn takeover offer by BHP Group Ltd for the Anglo American Group.
  • Acted for Actis who, together with Royal Bafokeng Holdings as its empowerment partner, acquired a 100% stake in Swiftnet SOC Limited from Telkom for an Enterprise Value of ZAR6.75bn.
  • Advised MultiChoice Group on Groupe Canal+’s acquisition of MultiChoice.

Bowmans

The 'extremely proactive and knowledgeable' tax team at Bowmans is highly adept at advising on the tax and regulatory aspects of international trade matters and routinely represents taxpayers in dealings with tax authorities. Co-leaders of the practice, Barry Garven and Mike Benetello, focus on tax litigation, M&A structuring, acquisition funding, mining taxation, and dispute resolution. Other key members of the department include Alan Keep, who advises corporate clients, Mark Linington, who specialises in M&A tax structuring, Robyn Berger, an expert in tax and exchange control, Mogola Makola, who is active in domestic and international tax work, banking and finance specialist Michael Rudnicki, and Wally Horak, who is notable in transfer pricing and expatriate secondments. Kelly Wright is another notable practitioner in the department.

Praxisleiter:

Barry Garven; Mike Benetello


Weitere Kernanwälte:

Alan Keep; Mark Linington; Robyn Berger; Mogola Makola; Michael Rudnicki; Wally Horak; Kelly Wright; Diwan Katoetie


Referenzen

‘Bowman’s tax team was extremely proactive and knowledgeable.‘

‚They provided excellent advice on South African tax matters in the M&A transactions we worked on together, delivering high-quality service throughout.‘

‘Very good team that we have been working with for a few years now.‘

Kernmandanten

Groupe Canal+ SA


Pick n Pay Retailers (Pty) Limited and Boxer Retail Limited


Infinite Partners Proprietary Limited


Convergence Partners Digital Infrastructure Fund


Inseego Corporation


AfriSam (South Africa) proprietary Limited


Coronation Investment Management SA Proprietary Limited


IDEAS Infrastructure II GP Proprietary Limited


Peermont Global Proprietary Limited


TotalEnergies


Compania Electrometalurgica S.A.


AECI Limited


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  • Advised Groupe Canal+ on its acquisition, through a mandatory offer contemplated in the Companies Act, of the JSE listed ordinary shares of the MultiChoice Group Limited not already owned by Canal+, a USD3bn transaction which won Deal of the Year at the 2025 DealMakers Awards.
  • Acted as tax advisors to Boxer Superstores and its parent company, Pick n Pay, in connection with the group’s capital raising exercises which included a rights offer concluded in August 2024 that preceded the listing of Boxer through an IPO in November 2024; the IPO raised ZAR8.5bn.
  • Acted as lead counsel for the Coronation group in a nine-year dispute with SARS regarding whether the income of Coronation’s Irish subsidiary should be taxed in South Africa; this has involved three appeals being heard in the Western Cape Tax Court, the Supreme Court of Appeal, and the Constitutional Court.

Werksmans Attorneys

Headed up by Doelie Lessing, the tax team at Werksmans Attorneys is lauded for its 'abundant skills' across the full-spectrum of tax matters, including assessments, negotiating settlements, and representing clients in the Tax Court, High Court, and Supreme Court of Appeal. Michael Honiball is knowledgeable in international tax law and transfer pricing, Ryan Killoran is adept in high-profile matters, and Ernest Mazansky specialises in corporate tax matters and restructuring work. Erich Bell is another key name focusing on double tax agreements, offshore acquisition, foreign trusts, and thin capitalism.

Praxisleiter:

Doelie Lessing


Weitere Kernanwälte:

Michael Honiball; Ryan Killoran; Ernest Mazansky; Erich Bell


Referenzen

‘Abundant skills across many members of the tax team.‘

‘Ernest Mazansky is widely regarded as an expert in corporate tax in South Africa.‘

‚Ernest Mazansky is innovative with an incredibly quick turn around time.’

Kernmandanten

Vivo Energy


Ntsimbintle Holdings Proprietary Limited


Ainsley Holdings Proprietary Limited


Transaction Capital Limited


Consortium of Banks comprised of The Standard Bank of South Africa Limited


Black Chrome Mine Proprietary Limited


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  • Advised Vitol Emerald Bidco (Pty) Ltd, a company within the broader Vitol Group, on the purchase of the shares in Engen Ltd from Petronas Marketing International Sendirian Berhad Petronas, a private company incorporated in accordance with the Laws of Malaysia.
  • Advised Transaction Capital Limited and its various subsidiaries involved on the unbundling of We Buy Cars Limited which then listed on the Johannesburg Stock Exchange.
  • Assisted Black Chrome Mine with all legal implications pertaining to their business rescue process which was concluded on 13 December 2024, including successfully regularising its pre and post commencement tax defaults, ensuring that the pre-commencement tax debts, including those arising from the tax defaults, were compromised by SARS in accordance with the business rescue plan and that such tax debts were not offset against the post-commencement refunds owing by SARS to BCM.

Baker McKenzie Johannesburg

Baker McKenzie Johannesburg offers comprehensive tax services, including international and corporate tax advice, assistance with transfer pricing and the tax elements of M&A transactions, VAT and customs-related matters, trade, and compliance work. The team is led by Verusha Subban, who specialises in customs, excise, and international trade, advising on complex cross-border tax, supply chain, and trade remedies across Africa. Denny Da Silva focuses on corporate tax, exchange control, and restructuring, and the team is also ably supported by Ursula Diale-Ali and Tsanga Mukumba.

Praxisleiter:

Verusha Subban


Weitere Kernanwälte:

Denny Da Silva; Ursula Diale-Ali; Tsanga Mukumba


Referenzen

‘Virusha Subban is always there to support. She is very attentive to the clients needs and you feel you are in good hands with her.‘

‘I was very pleased with the service, as it felt more like a collaboration. I was treated as though I was the only client.’

Kernmandanten

FT Marine t/a Orange Marine


Helios Towers (Pty) Ltd


Bidvest Office (Pty) Ltd.


Helios Towers (Pty) Ltd


The Foschini Group Ltd.


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CMS South Africa

Recognised for its 'personalised approach', CMS South Africa excels in exchange control, as well as litigious, transactional, and regulatory tax matters for domestic and international clients. Practice head Shaheed Patel advises on a wide range of tax matters, including the tax elements of M&A transactions, restructurings, investments, funding, executive share schemes, BEE transactions, and key withholding, capital gains, and indirect taxes. Thulaganyo Selokela has represented SARS in various tax disputes, while Naledi Mdingi is skilled in exchange control litigation.

Praxisleiter:

Shaheed Patel


Weitere Kernanwälte:

Thulaganyo Selokela; Naledi Mdingi


Referenzen

‘The team is highly involved in court matters even though counsel has been briefed.‘

‚They practice due diligence which ensures perfect delivery of legal services.’

‘During the consultation, our organisation worked with Thulaganyo Selokela. She demonstrated high level of attention to detail and knowledge in the field.‘

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