Tax Law

The inherent complexity of fiscal legislation makes tax law a highly specialised area of practice. The challenges posed by tax law are compounded by routine changes to tax legislation and increased enforcement by SARS in recent years. In this environment, it is critical to seek integrated, up-to-date, tax advice under the protection of legal professional privilege. Our tax & exchange control practice deals with a wide variety of matters that cover all tax types. We provide planning, advisory and transaction related services and our tax team is actively involved in dispute resolution and engagements with SARS.



  • Corporate tax planning and structuring advice
  • Group analysis and restructuring
  • VAT advisory and optimization
  • Personal income tax planning and trusts
  • International tax & cross-border transactions
  • Capital gains tax risk assessment
  • Tax optimised & compliant commercial agreements
  • Employee share incentive schemes
  • Employment Tax Incentive
  • Tax training and workshops

Exchange Control

  • Advice on Exchange Control Regulations.
  • Approval for inbound and outbound transactions and investments.
  • Engagement with Authorised Dealers and the Financial Surveillance Department of the SARB.

Opinions, Advance Rulings and Tax Directives

  • Compile and submit applications for advanced ruling from SARS to procure transactional certainty.
  • Provide general tax opinions on the tax treatment of structures, transactions and agreements.
  • Drafting tax opinions for purposes of section 223(3)(b) of the Tax Administration Act.
  • Procuring private opinions from SARS to obtain guidance on various tax matters.
  • Obtaining optimised tax directives on share vesting and lump sum payments.


Dispute Resolution

  • Responding to verification requests and SARS audits
  • Drafting of requests for suspension of disputed tax debts
  • Penalty abatement requests
  • Preparing objections and appeals
  • Representation in Alternative Dispute Resolution
  • Tax litigation
  • Settlement negotiations with SARS

Voluntary Disclosures

  • Compiling and submission of voluntary disclosure applications to regularise historic non-compliance in terms of the Voluntary Disclosure Programme under the Tax Administration Act.
  • Tax calculations and support
  • Responding to queries and liaising with SARS

Tax Debt Management

  • Drafting and negotiation of applications for tax debt reductions.
  • Negotiation of payment plans

Tax Administration

  • Reversal of irregular tax debt collection
  • Recovery of delayed VAT refunds
  • Expedited issuance of tax compliance certificates
  • Enforcement of prescribed time periods on SARS engagements and disputes
  • Challenging administrative SARS decisions