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2026 Edition

The tax team’s provision of tailored tax services covers clients active in various industries and sectors such as retail, energy, tech, IT and manufacturing on complex domestic and cross-border transactions. The practice has six specialised tax areas: controversy, TP, compliance and due diligence, indirect tax, corporate and transactional tax and HNWI advisory. Tax partner Virusha Subban heads the tax practice. 

At the end of 2022, the tax represented internet service firm Equinix on all tax matters regarding its 160 million data centre turnkey development and long-term lease transaction in Johannesburg.

The international law firm has one of the leading tax practices in South Africa and continues to enlarge its presence across the continent with new offices in Mauritius, Ethiopia and Zambia. The tax practice advises on tax controversy, compliance and non-contentious matters with in-depth experience in dispute resolution, corporate tax and international tax. Barry Garven and Wally Horak lead the tax practice comprising 24 practitioners.

The South African full-service law firm has a stand-alone tax practice offering tax advice on contentious and non-contentious tax matters. The comprehensive tax service coverage offers assistance on direct and indirect taxes, tax structuring, transactional tax, and more, for key players across various industries and sectors, such as financial services, real estate, energy and natural resources, mining, private equity, etc. With the leadership of tax partner and practice head Emil Brincker, the experienced tax team has seven dedicated tax partners, including Stephan Spamer, Gerhard Badenhorst, Ludwig Smith, Howmera Parak, Petr Erasmus, and Jerome Brink; each practitioner specialises in a specific tax domain. The Knowledge Management team is a separate support team focusing on legal technology developments to assimilate into the tax practice for enhancing and streamlining its tax services. This involves the use of AI, automation, and more, for quality and time efficiency.

The Big Four firm has one of the largest tax practices in South Africa, which offers full tax services on compliance, legal and general tax advisory matters. The experienced team is led by firm directors each specialising in various tax domains; firm partner Anthea Scholtz is one of the tax figures. In addition, managing director Itireleng Kubeka joined to the team in April 2022 from Absa Group. 

In the firm’s recent case studies presented describes the indirect tax team is representing clients in the energy and excise industry on suggested tax amendments to indirect tax and excise legislations for the fuel bunkering industry and cross-border transportation of alcoholic beverages.

ENS

ENS is well situated in South Africa with one of the largest tax practices and has the capacity to provide a one-stop-shop service, including transfer pricing compliance and advisory. The tax team’s services encompass cross-border corporate transactions, financial structuring, tax controversy, and more. Some tax areas the team has specialised in and gained extensive experience over the years are in M&A, VAT and customs, private client, and tax litigation. As one of the first law firms with a complete transfer pricing service offering, the team is well-regarded in the market for transfer pricing advisory, value chain analysis, characterisation of entities, economic analysis, transfer pricing policy design and implementation, and all transfer pricing compliance documentation. The key tax figures at the firm are tax partners Jens Brodbeck, Armaaz Camay, Peter Dachs, Charles De Wet, Robert Gad, Andries Myburgh, and Kristel Van Rensburg.      

In January 2025, the firm assisted Tencor Limited, an investment holding company, on the escrow unwinding and a potential delisted targeted by end of 2025. The transaction valuation from the start was estimated at 14 billion ZAR, 

Client feedback

“Experienced and high standard of technical skills. Practical feedback which is easy to implement and not overly burdensome. Prompt feedback and quick turnaround. 

Quick turn around on emails and queries raised via phone calls. Highly skilled and experienced, value her input and find her advice to be sound, practical and reliable.

EY

With one of the largest tax departments in South Africa, the Big Four firm’s tax practice consists of accounting technology attorneys, tax lawyers, accountants, engineers and more. Furthermore, the firm has a wealth of experience advising large-cap companies, domestic and multinational, such as Anglo American PLC, Anheuser-Busch InBev, Discovery Ltd, First Rand Ltd, MTN Group Ltd et c. Tax partner Ekow Eghan leads the tax practice consisting of more than seven tax partners.

Client feedback

''Pro-active, reasonably priced, quick response time, and a professional transfer pricing team (Cape Town Office).''

The global accountancy firm’s South African transfer pricing practice has grown in the past seven years since becoming fully operational, from a team of one practitioner to five. The team services the Mazars clients across the continent on all transfer pricing matters. Senior manager Charl Hall leads the practice.

The South African consulting firm specialises in transfer pricing issues across the continent since its inception in July 2017. The practice offers support in all transfer pricing matters; indeed, the team specialises in multi-country transfer pricing compliance projects, restructuring and advisory services, and transfer pricing controversy. Founder and firm director Michael Hewson leads the practice with the support of executive director Valdis Leikus and associate director April Nicholson who joined the firm in July 2022 from Deloitte.

Client feedback

''They study the business in detail and are able to relate to the industry to which we belong.''

''They meet their timelines and provide professional, high-quality documents for review. Graphene Economics understands my business. They have developed excellent relationships with key stakeholders that provide information for the TP documents.''

''Graphene is always willing to assist with ad hoc matters such as transfer pricing audits and controversy at short notice. Despite the size of the Vodacom engagement, Graphene has always provided advice of consistently high standard and within time and budget.''

Founded in 2021 by directors AJ Jansen van Nieuwenhuizen and Craig Bain, the consultancy firm offers full transfer pricing services to a variety of clients across the African continent. The services include policy development, structuring, compliance documentation preparation, benchmarking and CUP analysis, controversy assistance, APA guidance, revenue authority interaction and financial assistance advice  

During the last quarter of 2022, the firm assisted a manufacturing company with performing a debt capacity analysis and interest rate analysis, in addition to analysing cross-border intercompany transactions and preparing transfer pricing documentation

Client feedback

''Excellent knowledge on the subject and always willing to assist in quick time.''

 

The African law firm is highly recommended for its tax legal services, which the practice’s offerings cover general tax advisory and tax controversy support with in-depth experience providing innovative solutions in domestic and cross-border complex tax issues. Its client portfolio comprises large capital enterprises and medium-sized companies, private clients, non-profit organisations and more. The team has five partners, each specialising in specific tax areas. In mid-2022, the firm bolstered its tax practice with two partner promotions in Carryn Alexander and Lumen Moolman.

Client feedback

''Understands the business and the flow of transactions, and provides very precise views on its implications. This is supported by the interpretation of the law.''

''They give brilliant tax advice. Having worked with our various business units over the years, they understand the business strategy and their advice takes this into consideration. Their teams are well resourced and have diversity within.''

''Broad network, knowledge, and experience in jurisdictions applicable. Practical problem-solving approach and
good project management of various aspects.''

As the founding member of LEX Africa, a legal alliance of law firms across more than 25 African jurisdictions, the well-established South African law firm has three offices across Johannesburg, Cape Town, and Stellenbosch, offering full tax legal and compliance services with a breadth of experience in the commercial sector. The tax practice is led by Michael Honiball, head of international tax. However, tax partner Kyle Beilings left the team to join Standard Bank in January 2023. 

In March 2022, the firm assisted Real Foods Holdings Proprietary Limited on the tax aspects regarding developing the restructuring steps that would subsequently enable the merger of subsidiary firms Kauai and Nu businesses into VASAG, which ultimately served for the takeover by the acquirer Virgin Active.

Client feedback

''Excellent knowledge of tax law, trust law, and handling of tax disputes.''

''Technically very strong, pragmatic in approach, and very easy to interact with.''

Cliffe Dekker Hofmeyr
4 practice areas
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ENS
5 practice areas
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We are a full-service corporate law firm with a footprint across the African content , providing specialised legal services to local and international clients. Through our in-country and regional expertise, combined with our network of high-quality correspondent firms, we are able to assist you with all your legal and tax requirements, no matter where in Africa you choose to do business.
As Africa’s largest law firm, we are able to harness the expertise of our more than 600 practitioners based at 12 offices spread throughout the continent. Should your matter be situated in countries in Africa where we do not have presence or regional expertise, we are able to take advantage of our longstanding partnerships with formidable correspondent firms whom we work alongside in order to ensure the utmost quality of service is provided.

Our cross-border, continent-wide expertise is augmented by this broad network of firms with deeply local expertise, meaning that you receive expert legal advice from the most qualified legal advisors in each country. This approach makes us the African law firm of choice for cross-border legal advice throughout the continent.
We harness our deep specialist expertise in practice areas relevant to the project and at the correct level. This approach enables us to tailor-make solutions for your business needs, with the desired turnaround times and cost efficiencies.

You have the flexibility to choose a working arrangement with us that is best for your business, be it through a single point of contact, your own small, dedicated team of practitioners, or selected individuals.
We can advise you directly or work closely with your in-house legal team on projects so as to ensure that the end goal is achieved in the manner that best suits the assignment.

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Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
Spain did not transpose EU VAT rules for SMEs or works of art; in other news, an increased VAT threshold came into force in South Africa
Zion Adeoye, a tax specialist, had been suspended from the African law firm since October over misconduct allegations
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
Three tax experts dissect the impact of a 30% tariff that has shaken up trade relations between South Africa and the US
Specified taxpayers will have to apply a 19% VAT rate on services offered by third parties through their platforms; in other news, Donald Trump imposed 30% South African tariffs
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Meanwhile, South Africa’s finance minister has accepted a court decision on suspending a VAT increase and US President Donald Trump mulls a 100% tariff on foreign films
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