We offer practical advice on tax planning and compliance, in the highly specialised area of tax law. Both corporate and individual clients benefit from our extensive experience and our dedication to understanding and adapting to the complexities of our ever-changing tax laws.

Our tax department not only offers clients practical advice from a local and international perspective but also across departments throughout the firm making Fluxmans an ideal all-round legal solution for matters of all sizes.

Our services and areas of expertise include:

  • tax opinions – Income Tax, VAT, CGT, PAYE, Customs and ETI
  • objections, appeals and other tax litigation
  • Alternative Dispute Resolution (ADR)
  • tax settlements
  • Voluntary Disclosure Applications (VDP)
  • Criminal Tax Court representation
  • Africa tax

Corporate tax

  • corporate restructuring, unbundling, and corporate finance, including share repurchases, distributions and capital reductions, share buybacks, and capital and balance sheet restructuring
  • tax due diligence

International tax

  • inbound investment, including funding and thin capitalisation, withholding tax on outbound flows, and tax treaties
  • outbound investment, including controlled foreign companies, taxation of inbound flows, authorisation of foreign tax credits, and tax treaties
  • risk reviews
  • practical in-country advice, including tax and regulatory requirements, efficient in-country legal and operating structures, ongoing tax and regulatory compliance requirements, and assistance with queries from foreign tax authorities and other regulatory bodies

Private clients

  • advising high net worth individuals in respect of, among others, formation of local and foreign trusts, tax and exchange control matters, and estate planning
  • formation and tax optimisation of employee share incentive schemes and other arrangements
  • expatriate tax planning and compliance issues
  • tax planning: structuring employee packages for maximum tax efficiency
  • risk mitigation: ensuring compliance in order to sustain a tax audit
  • general tax advice: opinions and assistance with all employment-related tax issues

Value added tax (VAT)

  • VAT compliance reviews, advice and support
  • VAT training
  • VAT litigation and alternative dispute resolution
  • VAT consequences of agreements and transactions
  • Optimisation of VAT recovery/refunds
  • VAT system developments and implementation


  • customs and excise compliance reviews
  • customs and excise internal administrative appeals and litigation
  • application and defence of unfair trade practice investigations, including anti-dumping, countervailing, safeguarding and litigation in this regard
  • applying for and defending investigations into customs and excise duty increases and decreases, and duty refunds, rebates and exemptions, as well as litigation in this regard

Transfer pricing

  • transfer pricing advice
  • assist with transfer pricing documentation: preparing transfer pricing documentation based on the three-tiered approach endorsed by the Organisation for Economic Co-operation and Development (OECD), i.e. country-by-country reporting (CbCR), master file and local file, taking into account country-specific requirements
  • transfer pricing risk management and dispute resolution: assisting clients in respect of their interactions with the South African Revenue Service (SARS) and other tax authorities, from the initial risk assessment process to potential litigation

Dispute resolution

  • audits, investigations and queries
  • ensuring taxpayers’ rights are upheld
  • notices of objection
  • lodging appeals
  • managing tax litigation
  • settling disputes with tax authorities
  • utilising alternative dispute resolution, such as mediation

Exchange control

  • exchange control advice and required approvals for international transactions


Andre Kruger+27 11 328 1735