We frequently provide tax advice to a diverse spectrum of clients, including retail and investment banks, South African and international listed and unlisted companies and high net worth individuals. We also regularly liaise with and make representations to the South African Revenue Services on issues relating to new legislation, obtaining directives and dispute resolution.

OUR EXPERTISE

The constantly changing nature of the field of tax law, caused by regular changes to South Africa’s tax legislation, creates a need for access to specialised and professional tax advice. The Bowman Gilfillan tax law department offer a wide range of services. In particular, we can provide specialist advice on, inter alia:

• the tax structuring of mergers and acquisitions and capital market transactions;
• tax litigation;
• effective tax structuring of black economic empowerment transactions;
• international tax;
• transaction taxes;
• capital gains tax;
• liaison with SARS in respect of taxpayer’s affairs;
• mining tax;
• conducting alternative dispute resolution with SARS in respect of tax matters;
• effective structuring and group restructuring of groups of companies in South Africa;
• Value Added Tax (VAT);
• tax registration of charitable and public benefit organisations;
• cross border transactions and the application of double tax agreements;
• alternative dispute resolution of tax disputes;
• share incentive schemes and related tax issues.

OUR RECENT MATTERS INCLUDE:

• we advised ARMI in respect of the range of transactions which included the acquisition by Harmony of Avmin’s stake in Avgold, the acquisition of Avmin by ARMI’s stake in Harmony and certain joint ventures, which led to the renaming of Avmin as ARM;
  
  
• we advised Alcatel on the structuring of the sale of a portion of its South African interest to an empowerment consortium led by Four Seasons;
  
  
• we advised Ubuntu – Botho Investments Limited regarding the tax aspects of the acquisition of a stake in Sanlam Limited;
  
  
• we advised SA Chrome on the tax aspects of the joint venture arrangement with Xstrata Limited;
  
  
• we advised IBM on the South African tax aspect of the worldwide acquisition of the consulting division of PriceWaterhouseCoopers;
  
  
• we acted for Tiger Brands in reported cases relating to the levying of RSC levies on holding companies;
  
  
• we advised Barloworld on certain tax aspects in relation to the acquisition of the remaining shares in Avis Southern Africa Limited;
  
  
• we advised the UBS in relation to the restructuring of its affairs in South Africa;
  
  
• we advised General Motors with regard to its South African investments.