Heinrich Louw
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.
About Heinrich
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.
Credentials
Credentials
Education
- BA (Hons), University of Pretoria
- LLB, University of Pretoria
- LLM (Tax), University of Pretoria
- Year of admission as an attorney: 2012
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.
Credentials
Education
- BA (Hons), University of Pretoria
- LLB, University of Pretoria
- LLM (Tax), University of Pretoria
- Year of admission as an attorney: 2012
Experience
Tax and Exchange Control advice and opinions
Heinrich advises on all tax and exchange control aspects of commercial transactions, including mergers and acquisitions, corporate restructures, incentive schemes and empowerment transactions.
Tax dispute resolution
He has been involved in many tax objections and appeals, and has taken a number of cases to the tax court.
Advance tax rulings
Heinrich has assisted many clients in obtaining advance tax rulings in respect of commercial transactions.
Liquid fuel industry
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.
Chevron South Africa
Advised on empowerment transaction involving Chevron South Africa (Pty) Ltd
Puma Energy Group
Involved in restructuring of the Puma Energy group's South African interests
Total South Africa (Pty) Ltd
Defended tax assessments based on simulation for Total South Africa (Pty) Ltd
Harmony group
Obtained advance tax ruling for empowerment transaction in the Harmony group
WBHO
Advised on an incentive scheme for WBHO
News
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
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’
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...
Exchange control modernisation
In the 2020 Budget Speech it was announced that the National Treasury would embark on a substantive revision of the South African exchange control regime. It was anticipated that the...
Lay-by arrangements and debtors allowances
A lay-by arrangement can be characterised as one where a prospective purchaser agrees with a prospective seller that a particular item or asset will be set aside or reserved for purchase....
