Nicholas Carroll

Senior Associate

Nicholas Carroll is a Senior Associate in our Tax & Exchange Control practice. He has experience in commercial transaction structuring, employee share incentive schemes, tax due diligence, and matters involving tax controversy/dispute resolution.

+27 (0)21 481 6433

nicholas.carroll@cdhlegal.comCape Town

Nicholas Carroll

About Nicholas

Nicholas joined Cliffe Dekker Hofmeyr as a Candidate Attorney in 2021. After gaining experience in both the Dispute Resolution and Real Estate Law practice areas, he joined the Tax & Exchange Control practice area, where he was retained as an Associate in 2023.

Nicholas was promoted to Senior Associate in 2026.

Areas of expertise

Tax & Exchange Control

Experience

Advised OneLogix Group Limited in respect of its de-listing from the JSE.
Advised Mainstream Renewable Power in respect of its development of a 97.5 MW solar PV farm for the supply of electricity to Sasol and Air Liquide.
Advised the South African management team of M&C Saatchi in respect of their buy-out of the M&C Saatchi Abel business.
Advised Mainstream Renewable Power in respect of its development of a 50 MW solar PV farm.
Advised Coronation Fund Managers Limited in respect of its establishment of a BEE employee share ownership plan and a broad-based BEE ownership scheme, this deal subsequently winning the 2024 BEE Deal of the Year at the annual DealMakers awards.

Recognition

The Legal 500 EMEA 2025 - 2026 recommended Nicholas as a leading Associate in tax.

Credentials

Education

LLB (cum laude), Stellenbosch University
LLM – Tax Law (cum laude), University of Cape Town
Year of admission as an attorney and notary: 2023
Registered with the Legal Practice Council

LANGUAGES

English

News

The brackets stopped creeping and Christmas came early

Tax & Exchange Control

The brackets stopped creeping and Christmas came early

After three years of fiscal drag, income tax brackets have stopped creeping. But that is not all. After many years of the tax thresholds and exemptions in the ITA remaining stagnant,...

Is National Treasury gambling on taxpayers?

Tax & Exchange Control

Is National Treasury gambling on taxpayers?

The process to introduce a new tax takes time, careful consideration and public consultation. Therefore, the new online gambling tax proposed by National Treasury in a discussion paper...

PAJA now, argue later: SARS’ decision not to suspend payment can be subject to review

Tax & Exchange Control

PAJA now, argue later: SARS’ decision not to suspend payment can be subject to review

It is well-established that the function carried out by the South African Revenue Service (SARS) is administrative in nature. SARS’ actions are accordingly subject to the right of...

The new GAAR: This tax season's debutante

Tax & Exchange Control

The new GAAR: This tax season's debutante

Since their introduction in 2006, sections 80A to 80L of the Income Tax Act, 58 of 1962 (ITA) have been the subject of many a tax opinion and even more debate. Replacing the old section...

SARS v PAJA: The saga continues

Tax & Exchange Control

SARS v PAJA: The saga continues

Beginning most prominently with the original hearing of ABSA Bank Limited v Commissioner, SARS (3) SA 513 (GP) in the High Court (which we previously discussed here ), a taxpayer’s...

Taxpayers beware: SARS expects full compliance when objecting to assessments

Tax & Exchange Control

Taxpayers beware: SARS expects full compliance when objecting to assessments

Nicholas Carroll, Associate in the Tax & Exchange Control practice, recently joined Bridget Masinga on SAfm to discuss 'Taxpayers beware: SARS expects full compliance when objecting...

Kicking for touch - postponement of the budget speech

Tax & Exchange Control

Kicking for touch - postponement of the budget speech

In an unprecedented turn of events, the Minister of Finance’s scheduled Budget speech and introduction of the proposed national budget have been postponed until 12 March 2025. This...

Objecting to an additional assessment: When playing possum isn’t an option

Tax & Exchange Control

Objecting to an additional assessment: When playing possum isn’t an option

When a taxpayer is aggrieved by an assessment raised by the South African Revenue Service (SARS), the first step in disputing this is to file an objection under section 104 of the...

To BEE or not to BEE

To BEE or not to BEE

Corporate taxpayers often face the question of how to increase their broad-based Black economic empowerment (B-BBEE) credentials through equity ownership schemes. While it is important...

Transfer pricing has finally washed up on South Africa’s shores

Tax & Exchange Control

Transfer pricing has finally washed up on South Africa’s shores

With increasing economic globalisation, revenue authorities around the world continue to shift their focus to issues of transfer pricing. Broadly, this fits in with the global move...

SARS giveth and SARS taketh away

SARS giveth and SARS taketh away

The alarmingly high unemployment rate in South Africa has given rise to several tax incentives for employers to grow their workforces. One of these is the Employment Tax Incentive...

Tax Vertical mergers are back

Tax & Exchange Control

Tax Vertical mergers are back

Section 44 of the Income Tax Act 58 of 1962 (Tax Act) is one of the lesser used of the so-called “ corporate rollover relief rules ”, but is nevertheless one of the more hotly contested....

Don’t go banking on review

Tax & Exchange Control

Don’t go banking on review

The ability to review our revenue service’s decisions in the High Court is a question that has plagued South Africa’s legal system since the amendment of section 105 of the Tax Administration...

Adjusting a definition

Tax & Exchange Control

Adjusting a definition

The circular reference error is a scourge that has plagued many tax practitioners’ spreadsheets since the amendment to section 20 of the Income Tax Act 58 of 1962 (ITA) at the end...

At it again: Capital v revenue

Tax & Exchange Control

At it again: Capital v revenue

The capital versus revenue debate is as old as tax law itself. The benefits, advantages or consequences of an amount being considered capital or revenue in nature has motivated taxpayers...

Tax exceptionalism in circumstance

Tax & Exchange Control

Tax exceptionalism in circumstance

Love it or hate it, tax exceptionalism (the idea that, due to its specialised nature, tax law operates within its own parameters) tends to arise when tax disputes cross the boundary...

All articles by Nicholas

The brackets stopped creeping and Christmas came early

Tax & Exchange Control

The brackets stopped creeping and Christmas came early

After three years of fiscal drag, income tax brackets have stopped creeping. But that is not all. After many years of the tax thresholds and exemptions in the ITA remaining stagnant,...

Is National Treasury gambling on taxpayers?

Tax & Exchange Control

Is National Treasury gambling on taxpayers?

The process to introduce a new tax takes time, careful consideration and public consultation. Therefore, the new online gambling tax proposed by National Treasury in a discussion paper...

PAJA now, argue later: SARS’ decision not to suspend payment can be subject to review

Tax & Exchange Control

PAJA now, argue later: SARS’ decision not to suspend payment can be subject to review

It is well-established that the function carried out by the South African Revenue Service (SARS) is administrative in nature. SARS’ actions are accordingly subject to the right of...

The new GAAR: This tax season's debutante

Tax & Exchange Control

The new GAAR: This tax season's debutante

Since their introduction in 2006, sections 80A to 80L of the Income Tax Act, 58 of 1962 (ITA) have been the subject of many a tax opinion and even more debate. Replacing the old section...

SARS v PAJA: The saga continues

Tax & Exchange Control

SARS v PAJA: The saga continues

Beginning most prominently with the original hearing of ABSA Bank Limited v Commissioner, SARS (3) SA 513 (GP) in the High Court (which we previously discussed here ), a taxpayer’s...

Kicking for touch - postponement of the budget speech

Tax & Exchange Control

Kicking for touch - postponement of the budget speech

In an unprecedented turn of events, the Minister of Finance’s scheduled Budget speech and introduction of the proposed national budget have been postponed until 12 March 2025. This...

Objecting to an additional assessment: When playing possum isn’t an option

Tax & Exchange Control

Objecting to an additional assessment: When playing possum isn’t an option

When a taxpayer is aggrieved by an assessment raised by the South African Revenue Service (SARS), the first step in disputing this is to file an objection under section 104 of the...

To BEE or not to BEE

To BEE or not to BEE

Corporate taxpayers often face the question of how to increase their broad-based Black economic empowerment (B-BBEE) credentials through equity ownership schemes. While it is important...

Transfer pricing has finally washed up on South Africa’s shores

Tax & Exchange Control

Transfer pricing has finally washed up on South Africa’s shores

With increasing economic globalisation, revenue authorities around the world continue to shift their focus to issues of transfer pricing. Broadly, this fits in with the global move...

SARS giveth and SARS taketh away

SARS giveth and SARS taketh away

The alarmingly high unemployment rate in South Africa has given rise to several tax incentives for employers to grow their workforces. One of these is the Employment Tax Incentive...

Tax Vertical mergers are back

Tax & Exchange Control

Tax Vertical mergers are back

Section 44 of the Income Tax Act 58 of 1962 (Tax Act) is one of the lesser used of the so-called “ corporate rollover relief rules ”, but is nevertheless one of the more hotly contested....

Don’t go banking on review

Tax & Exchange Control

Don’t go banking on review

The ability to review our revenue service’s decisions in the High Court is a question that has plagued South Africa’s legal system since the amendment of section 105 of the Tax Administration...

Adjusting a definition

Tax & Exchange Control

Adjusting a definition

The circular reference error is a scourge that has plagued many tax practitioners’ spreadsheets since the amendment to section 20 of the Income Tax Act 58 of 1962 (ITA) at the end...

At it again: Capital v revenue

Tax & Exchange Control

At it again: Capital v revenue

The capital versus revenue debate is as old as tax law itself. The benefits, advantages or consequences of an amount being considered capital or revenue in nature has motivated taxpayers...

Tax exceptionalism in circumstance

Tax & Exchange Control

Tax exceptionalism in circumstance

Love it or hate it, tax exceptionalism (the idea that, due to its specialised nature, tax law operates within its own parameters) tends to arise when tax disputes cross the boundary...

All articles by Nicholas

Taxpayers beware: SARS expects full compliance when objecting to assessments

Tax & Exchange Control

Taxpayers beware: SARS expects full compliance when objecting to assessments

Nicholas Carroll, Associate in the Tax & Exchange Control practice, recently joined Bridget Masinga on SAfm to discuss 'Taxpayers beware: SARS expects full compliance when objecting...

All podcasts by Nicholas

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