Stephan Spamer

Director

Stephan Spamer in a Director in our Tax & Exchange Control practice.

Stephan Spamer

About Stephan

Before joining Cliffe Dekker Hofmeyr, Stephan headed the Tax Department at Baker McKenzie (South Africa) and prior to that was a Tax Partner at ENSafrica.

Areas of expertise

Tax & Exchange Control
Pensions & Employee Benefits

Experience

  • Stephan is a corporate and international tax lawyer with vast experience in advising on domestic and international tax matters, transaction structuring and mergers and acquisitions. 

  • Stephan’s experience includes advising companies (across various industries) on the tax implications applicable to a broad range of transactions, including merger and acquisition transactions (tax due diligence investigations and tax-efficient transaction structuring advice), management share incentive schemes, Employee Share Ownership Plans (ESOP),  Black Economic Empowerment (BEE) transactions, private equity transactions, financing/funding arrangements and corporate restructures.

  • From a tax dispute resolution perspective, Stephan assists companies in responding to various audits/investigations from revenue authorities, preparing and lodging objections and appeals, alternative tax dispute resolution and tax court matters.

  • Stephan advises private clients, family offices, domestic and international financial institutions and trust companies, and frequently speaks on trusts, financial services and compliance issues at wealth management and trust and estate planning conferences. In this regard Stephan's practice focuses on the use of sophisticated wills, trusts, closely held entities, as well as tax exempt (charitable) entities. Stephan represents clients with worldwide assets in estate, trust, tax and tax exempt/not-for-profit organization matters.

Recognition

  • Chambers Global 2019–2026 ranked Stephan Spamer in Band 3 for tax.
  • The Legal 500 EMEA 2021–2025 recommended him for tax.
  • 2025 - 2026 ITR World Tax Rankings ranked Stephan as 'Highly Regarded' in general corporate tax and transaction tax in South Africa.

     

Credentials

Education

  • B.Comm/LLB, University of Stellenbosch
  • Registered with the Legal Practice Council

Memberships

  • Registered Tax Practitioner
  • Commissioner of the Small Claims Court of South Africa
  • Tax Committee of the International Bar Association

LANGUAGES

  • English

News

CDH Tax & Exchange Control experts recognised among the best in the 2026 ITR World Tax Rankings
Firm News

CDH Tax & Exchange Control experts recognised among the best in the 2026 ITR World Tax Rankings

Our Tax & Exchange Control experts have been recognised among the top professionals in the newly released 2026 ITR World Tax rankings, further cementing our firm’s reputation for excellence...

CDH Tax & Exchange Control experts ranked among the best by 2025 ITR World Tax
Firm News

CDH Tax & Exchange Control experts ranked among the best by 2025 ITR World Tax

Cliffe Dekker Hofmeyr (CDH), a leading corporate and commercial law firm, is proud to be recognised for our expertise in tax in the recently released 2025 ITR World Tax Rankings.

Revisions to the definition of “value-shifting arrangement” in the context of group reorganisation transactions

Revisions to the definition of “value-shifting arrangement” in the context of group reorganisation transactions

The notion of shifting value between shareholders of a company is generally a concern of revenue authorities in that, once a value shift takes place, one shareholder receives the benefit...

Amendments in relation to purported loopholes in foreign capital participation exemption
Tax & Exchange Control

Amendments in relation to purported loopholes in foreign capital participation exemption

Like many countries South Africa has a “ participation exemption ” which exempts returns in the form of both foreign dividends or foreign capital realised by South African residents,...

Closing a targeted scheme abusing the tax implications inherent to contributed tax capital
Tax & Exchange Control

Closing a targeted scheme abusing the tax implications inherent to contributed tax capital

The “ contributed tax capital ” (CTC) of a company is a notional tax concept that denotes an amount derived from the value of any contribution (typically a subscription price) made...

Proposals in relation to the retirement fund industry

Proposals in relation to the retirement fund industry

The Minister of Finance has announced various proposed amendments to the taxation regime of retirement funds which we discuss below.

Tax and exchange control considerations for South African tax residents taking up employment in the UAE
Tax & Exchange Control

Tax and exchange control considerations for South African tax residents taking up employment in the UAE

Because South Africa (SA) follows a residence-based tax system, SA residents are taxed on their worldwide income, irrespective of the jurisdictional source of their income. This means...

Public Benefit Organisations and the special tax dispensation under the Disaster Management Tax Relief Bill

Public Benefit Organisations and the special tax dispensation under the Disaster Management Tax Relief Bill

The Disaster Management Tax Relief Bill (Tax Relief Bill) was introduced at the beginning of April 2020 after President Cyril Ramaphosa first announced that tax relief measures would...

CDH Tax & Exchange Control experts recognised among the best in the 2026 ITR World Tax Rankings
Firm News

CDH Tax & Exchange Control experts recognised among the best in the 2026 ITR World Tax Rankings

Our Tax & Exchange Control experts have been recognised among the top professionals in the newly released 2026 ITR World Tax rankings, further cementing our firm’s reputation for excellence...

CDH Tax & Exchange Control experts ranked among the best by 2025 ITR World Tax
Firm News

CDH Tax & Exchange Control experts ranked among the best by 2025 ITR World Tax

Cliffe Dekker Hofmeyr (CDH), a leading corporate and commercial law firm, is proud to be recognised for our expertise in tax in the recently released 2025 ITR World Tax Rankings.

Revisions to the definition of “value-shifting arrangement” in the context of group reorganisation transactions

Revisions to the definition of “value-shifting arrangement” in the context of group reorganisation transactions

The notion of shifting value between shareholders of a company is generally a concern of revenue authorities in that, once a value shift takes place, one shareholder receives the benefit...

Amendments in relation to purported loopholes in foreign capital participation exemption
Tax & Exchange Control

Amendments in relation to purported loopholes in foreign capital participation exemption

Like many countries South Africa has a “ participation exemption ” which exempts returns in the form of both foreign dividends or foreign capital realised by South African residents,...

Closing a targeted scheme abusing the tax implications inherent to contributed tax capital
Tax & Exchange Control

Closing a targeted scheme abusing the tax implications inherent to contributed tax capital

The “ contributed tax capital ” (CTC) of a company is a notional tax concept that denotes an amount derived from the value of any contribution (typically a subscription price) made...

Proposals in relation to the retirement fund industry

Proposals in relation to the retirement fund industry

The Minister of Finance has announced various proposed amendments to the taxation regime of retirement funds which we discuss below.

Tax and exchange control considerations for South African tax residents taking up employment in the UAE
Tax & Exchange Control

Tax and exchange control considerations for South African tax residents taking up employment in the UAE

Because South Africa (SA) follows a residence-based tax system, SA residents are taxed on their worldwide income, irrespective of the jurisdictional source of their income. This means...

Public Benefit Organisations and the special tax dispensation under the Disaster Management Tax Relief Bill

Public Benefit Organisations and the special tax dispensation under the Disaster Management Tax Relief Bill

The Disaster Management Tax Relief Bill (Tax Relief Bill) was introduced at the beginning of April 2020 after President Cyril Ramaphosa first announced that tax relief measures would...

From vision to fruition.