matters

Recent transactions in which we have provided tax advice include:

• Davis Langdon Africa (Pty) Ltd in the South African and African legs of a transaction whereby AECOM Technology Corporation purchased the business and assets of Davis Langdon in each of Australia, New Zealand, Europe, the Middle East, the United States, Africa and South Africa. The transactions have a combined value of US$ 324 million (approximately R2,24 billion);
• Bharti Airtel Ltd on its proposed transaction with MTN Group Limited;
• SABMiller on the disposal of a 10% interest in SAB Limited to facilitate black economic empowerment;
• Standard Bank Group Limited in relation to the acquisition of a 20% interest in our client by Industrial and Commercial Bank of China Limited, value of R36,7 billion, at that time the largest inbound investment into South Africa in history;
• Mvelaphanda Resources on the proposed unbundling of its interest in Northam and the proposed acquisition of it by Impala Platinum;
• Verizon on the disposal of its Southern Africa business to MTN;
• Nampak in respect of their tax dispute with the South African Revenue Service related to their acquisition of the Malbak group;
• Tongaat Hulett in respect of its black economic empowerment transaction and the unbundling and listing of Hulamin Limited;
• Barloworld Limited on the unbundling of its majority interest in PPC;
• Merrill Lynch South Africa on its black economic empowerment transaction;
• The Standard Bank of South Africa Limited on the issue of Tier II Capital subordinated notes;
• Cisco Systems Inc on its black economic empowerment transaction involving its South African operation entities;
• Goldman Sachs on forward trades and other derivatives;
• Barloworld Limited in the disposal of an effective 25% interest relative to its South African operations to black economic empowerment investors;
• Lehman Brothers Merchant Bank Fund 5 in the acquisition of a 10% interest in a South African health care entity;
• Barrick Gold Corporation on the disposal of its interest in the South Deep mine and various South African investments;
• Morgan Stanley International in relation to various derivative financing transactions with South African counterparties;
• Ethos Private Equity in respect of the structuring of their Fund IV and structuring investments made by Fund V and in discussions with SARS/Treasury in respect of a new tax dispensation for private equity transactions;
• Anglo Platinum regarding the restructure of their offshore subsidiaries/holding structure.