tax law

The Bowman Gilfillan tax practice provides thoroughly considered and legally sound transactional tax advice to local and international financial institutions, corporates and individuals. The tax practice aims to combine its commercial and tax law expertise to provide efficient tax solutions.

The Bowman Gilfillan tax practice is also fully equipped to support clients in tax disputes and aims to resolve disputes as amicably as possible without sacrificing its clients' rights.

Our tax practice is integrated within the firm's corporate offices in Johannesburg and Cape Town.

The constantly changing nature of tax law, as a result of court decisions and regular changes to South Africa's tax legislation, creates a need for specialised and professional tax advice. For this reason, over the past few years, Bowman Gilfillan has developed its tax practice through organic growth and strategic lateral hires. Today, our tax practice comprises seven experienced tax partners and a professional support team. The tax team offers both depth and breadth in respect of their tax law skills and thorough knowledge base.

The members of our tax practice regularly contribute to publications and write articles on developing tax law. We work closely with the rest of the firm to ensure that the tax aspects of any transaction are thoroughly considered and planned. We also regularly liaise with and make representations to National Treasury and the South African Revenue Service regarding legislative amendments affecting our clients, and the obtaining of tax directives.


  • Chambers Global 2015 ranked Wally Horak and Alan Keep as leaders in their field. The tax practice was ranked in Band 2.
  • Legal 500 EMEA 2015 ranked our practice in second tier. With sources saying, "Bowman Gilfillan’s department remains well acquainted with international investment banks as well as several domestic institutions. In addition, the practice regularly works with foreign multinationals. Wally Horak is one of the doyens of international taxation, has ‘detailed knowledge’ of double tax treaties, and frequently works with private equity and venture capital funds. Clients commend the firm’s ‘extensive network’, its ‘industry knowledge’ and its ‘value for money’."
  • Managing partner Alan Keep and Barry Garven are also highly recommended.
  • PLC Which? Lawyer ranked the Bowman Gilfillan Tax practice Band 2.

Our Expertise

The Bowman Gilfillan Tax practice offers a wide range of services to clients all of which are provided by tax partners who specialise in the particular field. Examples of the type of services that we provide include:

  • Structuring all aspects of investments made into South Africa by foreign corporates
  • Structuring of debt and equity funding provided by local and international financial institutions
  • Tax advice on all aspects of mergers and acquisitions, including outbound and inbound cross-border transactions
  • Tax due diligence investigations and other investigations aiming at minimising and optimising tax charges
  • Advising local corporates on their international investments, including exchange control advice, tax treaty planning, effective management issues and all other tax considerations of international investments
  • All aspects of tax litigation including assistance with South African Revenue Service's queries, audits, objections, appeals, alternative dispute resolution and the negotiation of settlements of tax disputes
  • Providing tax advice on all types of commercial agreements
  • The formation of private equity funds and advice on private equity transactions
  • Commercial property transactions
  • Intellectual property transactions
  • Capital gains tax
  • Dividend tax
  • Employees' tax Restructuring of groups of companies in South Africa
  • Planning black economic empowerment transactions
  • Mining tax
  • Share and other incentive schemes and related tax issues for both BEE and general commercial transactions
  • Planning, formation and registration of public benefit organisations
  • Advising public private partnerships and modelling and maintaining comparative tax computations over life of contract Transaction tax planning, including
  • Securities Transfer Tax
  • Value Added Tax (VAT) Customs, excise and international trade related aspects of imports, exports and local manufacturing of goods
  • Anti-dumping; countervailing and safeguard duties
  • Provision of outsourced tax managerial functions, which include continuous tax planning via tax committees

Clients And Recent Deals

Recent transactions in which we have provided tax advice include advice to:

  • Advising a full service global investment banking and securities firm on South African Securities Transfer Tax aspects of foreign exchange traded shares
  • Advising Fountainhead Property Trust on offers to acquire its assets from Redefine and Growthpoint
  • Advising a professional football club on the tax treatment of the acquisition of publicity rights from players
  • Advising many South African subsidiaries of a listed company on the tax treatment of its share incentive schemes
  • Advising on the re-organisation and debt restructuring of the AfriSam group of companies, being one of the largest debt restructuring exercises in South Africa
  • Advising on the sale of the UCS Solutions businesses to Business Connexion; and on the unbundling of the UCS Solutions assets and the de-listing of UCS Group Limited
  • Advising the Marsh and McLennan group of companies on the acquisition of the Alexander Forbes Risk Services businesses in South Africa and elsewhere in Africa
  • Advising SAB Miller and SAB Limited on the BEE transaction implemented by SAB Limited Advising Standard Bank on its business name arrangement with Liberty Life
  • Advising Mr F Giurich on the disposal of properties to Investec Property Fund Advising Northam Limited on the sale of certain of its mining assets
  • Advising on all aspects of limited risk distribution and contract manufacturing
  • Advising Brazilian exporters in relation to the anti-dumping investigation initiated by the South African Poultry Association on chicken products imported from Brazil
  • Advising a large motor vehicle manufacturer on the import of remanufactured parts into South Africa
  • Advising the freight forwarding industry in relation to the changes to the Customs legislation in South Africa
  • Tax advice in relation to the listing of a property fund
  • Advising various financial institutions on the tax consequences of preference share funding under the amended section 8E and section 8EA
  • Advising AECOM Technology Corporation, a leading engineering consultancy listed on the New York Stock Exchange, in its acquisition of the consulting engineering firm BKS Group. The deal has a value of about R300 million and the acquisition was announced on the NYSE on Friday 2 November.

Bowman Gilfillan is one of the South Africa’s premier tax law firms.

In order to adequately comply with tax law and avoid unnecessary legal issues, it is essential to seek the advice of a professional tax lawyer. Bowman Gilfillan can help you to navigate South Africa’s tax legislation as well as assist you with any other tax law concern.

Contact us now to consult one of our experienced tax attorneys.



In association with Bowman Gilfillan Africa GroupMember of Lex MundiMember of Employment Law Alliance