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Heinrich Louw

Director

Heinrich Louw is a Director in our Tax & Exchange Control practice. He has experience in various tax and exchange control matters relating to commercial transactions, as well as dispute resolution involving the South African Revenue Service.

+27 (0)11 562 1187
heinrich.louw@cdhlegal.comJohannesburg
Heinrich Louw

About Heinrich

Heinrich joined Cliffe Dekker Hofmeyr as a Candidate Attorney in 2010. He was retained as an Associate in 2012 and promoted to Senior Associate in 2014. Heinrich was appointed as a Director in 2018.

Areas of expertise

Tax & Exchange ControlOil & Gas

Experience

  • Heinrich advises on all tax and exchange control aspects of commercial transactions, including mergers and acquisitions, corporate restructures, incentive schemes and empowerment transactions.

  • He has been involved in many tax objections and appeals, and has taken a number of cases to the tax court.

  • Heinrich has assisted many clients in obtaining advance tax rulings in respect of commercial transactions.

  • Heinrich also generally advises on commercial matters in the fuel industry, including the importation and manufacture of fuel products, wholesale supply, retail supply and the transportation of fuel. He has experience in the drafting of fuel supply agreements (including aviation fuel – into plane and bulk supply), retail dealer agreements (CODO and DODO), leases in respect service stations, transport agreements and throughput agreements.

  • Advised on empowerment transaction involving Chevron South Africa (Pty) Ltd

  • Involved in restructuring of the Puma Energy group's South African interests

  • Defended tax assessments based on simulation for Total South Africa (Pty) Ltd

  • Obtained advance tax ruling for empowerment transaction in the Harmony group

  • Advised on an incentive scheme for WBHO

Credentials

Education

  • BA (Hons), University of Pretoria
  • LLB, University of Pretoria
  • LLM (Tax), University of Pretoria
  • Year of admission as an attorney: 2012

 

LANGUAGES

  • English

News

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...
Know your grounds: Why SARS must explain assessments
Tax & Exchange Control

Know your grounds: Why SARS must explain assessments

A taxpayer’s ability to challenge an assessment issued by the South African Revenue Service (SARS) stems from the fundamental rights to just administrative action and access to courts....
Company tax debts
Tax & Exchange Control

Company tax debts

Heinrich Louw, Director in the Tax & Exchange Control practice, was recently featured in the Sunday Times Supplement, where he discussed 'Company tax debts.'
Avoiding unexpected tax liabilities in property investment
Tax & Exchange Control

Avoiding unexpected tax liabilities in property investment

Property investment is a popular topic of discussion, often accompanied by various anecdotes, tips, and cautionary tales. However, while the potential for profit is frequently emphasised,...
No hiding from tax debt: court backs SARS in major legal win
Tax & Exchange Control

No hiding from tax debt: court backs SARS in major legal win

Heinrich Louw, Director in the Tax & Exchange Control, was recently featured on Channel Africa, where he discussed 'No hiding from tax debt: court backs SARS in major legal win.'
Bringing (and keeping) home the bacon: SARS’ repatriation and collection powers affirmed
Tax & Exchange Control

Bringing (and keeping) home the bacon: SARS’ repatriation and collection powers affirmed

Sections 180, 184(2) and 186(3) of the Tax Administration Act 28 of 2011 (TAA) grant the South African Revenue Service (SARS) significant powers to recover tax debts from third parties responsible...
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...
Exchange control update: Payment of royalties and fees by residents to related non-residents now tied to transfer pricing requirements
Tax & Exchange Control

Exchange control update: Payment of royalties and fees by residents to related non-residents now tied to transfer pricing requirements

For a very long time, residents have been required to obtain prior approval from the Financial Surveillance Department of the South African Reserve Bank (SARB) when making payment...
Can SARS limit access to a taxpayer’s premises when carrying out an inspection?
Tax & Exchange Control

Can SARS limit access to a taxpayer’s premises when carrying out an inspection?

Judgment was handed down in the case of Alliance Fuel (Pty) Ltd and Inspacial Properties (Pty) Ltd v Commissioner for the South African Revenue Service in the High Court on 15October2024. 
Understatement penalties and the benefit of tax opinions: A review of the <em>Thistle Trust</em> saga
Tax & Exchange Control

Understatement penalties and the benefit of tax opinions: A review of the Thistle Trust saga

We previously reported on the judgment by the Supreme Court of Appeal (SCA) in the case of CSARS v The Thistle Trust (516/2021) ZASCA 153 (7 November 2022) in our Tax alert of 24 November...
There is no greatness in your lateness: Not sticking to the Tax Court Rules in respect of discovery
Tax & Exchange Control

There is no greatness in your lateness: Not sticking to the Tax Court Rules in respect of discovery

Earlier this year, the Tax Court handed down judgment in the matter of CZY (In liquidation) v The Commissioner for the South African Revenue Service (Case No.: IT 45997) ( 27February2024). The matter...
A few changes relating to controlled foreign companies

A few changes relating to controlled foreign companies

A controlled foreign company (CFC) is essentially a foreign company where 50% or more of its shares or voting rights are collectively held by South African residents.
Lexology - In-Depth: Oil and Gas - South Africa
Oil & Gas

Lexology - In-Depth: Oil and Gas - South Africa

Directors HeinrichLouw, Megan Rodgers and Associate Amore Carstens contributed to the South African chapter of the Lexology - In-Depth: Oil and Gas Law - Edition 11 .
Review of “qualifying purpose” in the context of third-party backed shares
Tax & Exchange Control

Review of “qualifying purpose” in the context of third-party backed shares

Readers may recall Binding Private Ruling 379, which was issued by SARS on 3 October 2022.
Understatement penalties and bona fide inadvertent errors
Tax & Exchange Control

Understatement penalties and bona fide inadvertent errors

As taxpayers may be aware, should they cause or make an “ understatement ”, they may be liable to the South African Revenue Service (SARS) for an understatement penalty in terms of...
Section 9 of the Tax Administration Act as an ‘internal remedy’
Tax & Exchange Control

Section 9 of the Tax Administration Act as an ‘internal remedy’

Section 9(1) of the Tax Administration Act 28 of 2011 (TAA) effectively provides for a taxpayer to request a South African Revenue Service (SARS) official to withdraw or amend either...

All articles by Heinrich
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...
Know your grounds: Why SARS must explain assessments
Tax & Exchange Control

Know your grounds: Why SARS must explain assessments

A taxpayer’s ability to challenge an assessment issued by the South African Revenue Service (SARS) stems from the fundamental rights to just administrative action and access to courts....
Company tax debts
Tax & Exchange Control

Company tax debts

Heinrich Louw, Director in the Tax & Exchange Control practice, was recently featured in the Sunday Times Supplement, where he discussed 'Company tax debts.'
Avoiding unexpected tax liabilities in property investment
Tax & Exchange Control

Avoiding unexpected tax liabilities in property investment

Property investment is a popular topic of discussion, often accompanied by various anecdotes, tips, and cautionary tales. However, while the potential for profit is frequently emphasised,...
Bringing (and keeping) home the bacon: SARS’ repatriation and collection powers affirmed
Tax & Exchange Control

Bringing (and keeping) home the bacon: SARS’ repatriation and collection powers affirmed

Sections 180, 184(2) and 186(3) of the Tax Administration Act 28 of 2011 (TAA) grant the South African Revenue Service (SARS) significant powers to recover tax debts from third parties responsible...
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...
Exchange control update: Payment of royalties and fees by residents to related non-residents now tied to transfer pricing requirements
Tax & Exchange Control

Exchange control update: Payment of royalties and fees by residents to related non-residents now tied to transfer pricing requirements

For a very long time, residents have been required to obtain prior approval from the Financial Surveillance Department of the South African Reserve Bank (SARB) when making payment...
Can SARS limit access to a taxpayer’s premises when carrying out an inspection?
Tax & Exchange Control

Can SARS limit access to a taxpayer’s premises when carrying out an inspection?

Judgment was handed down in the case of Alliance Fuel (Pty) Ltd and Inspacial Properties (Pty) Ltd v Commissioner for the South African Revenue Service in the High Court on 15October2024. 
Understatement penalties and the benefit of tax opinions: A review of the <em>Thistle Trust</em> saga
Tax & Exchange Control

Understatement penalties and the benefit of tax opinions: A review of the Thistle Trust saga

We previously reported on the judgment by the Supreme Court of Appeal (SCA) in the case of CSARS v The Thistle Trust (516/2021) ZASCA 153 (7 November 2022) in our Tax alert of 24 November...
There is no greatness in your lateness: Not sticking to the Tax Court Rules in respect of discovery
Tax & Exchange Control

There is no greatness in your lateness: Not sticking to the Tax Court Rules in respect of discovery

Earlier this year, the Tax Court handed down judgment in the matter of CZY (In liquidation) v The Commissioner for the South African Revenue Service (Case No.: IT 45997) ( 27February2024). The matter...
A few changes relating to controlled foreign companies

A few changes relating to controlled foreign companies

A controlled foreign company (CFC) is essentially a foreign company where 50% or more of its shares or voting rights are collectively held by South African residents.
Lexology - In-Depth: Oil and Gas - South Africa
Oil & Gas

Lexology - In-Depth: Oil and Gas - South Africa

Directors HeinrichLouw, Megan Rodgers and Associate Amore Carstens contributed to the South African chapter of the Lexology - In-Depth: Oil and Gas Law - Edition 11 .
Review of “qualifying purpose” in the context of third-party backed shares
Tax & Exchange Control

Review of “qualifying purpose” in the context of third-party backed shares

Readers may recall Binding Private Ruling 379, which was issued by SARS on 3 October 2022.
Understatement penalties and bona fide inadvertent errors
Tax & Exchange Control

Understatement penalties and bona fide inadvertent errors

As taxpayers may be aware, should they cause or make an “ understatement ”, they may be liable to the South African Revenue Service (SARS) for an understatement penalty in terms of...
Section 9 of the Tax Administration Act as an ‘internal remedy’
Tax & Exchange Control

Section 9 of the Tax Administration Act as an ‘internal remedy’

Section 9(1) of the Tax Administration Act 28 of 2011 (TAA) effectively provides for a taxpayer to request a South African Revenue Service (SARS) official to withdraw or amend either...

All articles by Heinrich
No hiding from tax debt: court backs SARS in major legal win
Tax & Exchange Control

No hiding from tax debt: court backs SARS in major legal win

Heinrich Louw, Director in the Tax & Exchange Control, was recently featured on Channel Africa, where he discussed 'No hiding from tax debt: court backs SARS in major legal win.'

All podcasts by Heinrich

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