Stephan Spamer

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.

In addition, 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 organisation matters.

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.

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.

In addition, 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 organisation matters.

Representative Legal Matters

• Acted as the lead tax advisor for South32 (South Africa and Africa).
• Providing corporate tax advice to a number of South African based mining companies, including but not limited to BHP Billiton, Anglo American, Anglo Platinum, AngloGold Ashanti, Barplats/Eastplats, Goldfields, United Manganese and Metorex.
• Acted as lead tax adviser with respect to the structuring and implementation of various employee incentive schemes, including a ZAR1.86 billion employee share scheme in for ArcelorMittal.
• Advised various aviation companies on structuring their commercial operations across Africa, the implementation international and African business operations and the tax structuring thereof.
• Acted as lead tax adviser to an insurance company in connection with the ZAR2.3 billion acquisition of shares in another insurance company.
• Advised various companies on the tax issues related to their offshore holding structures and African business operations, including providing tax advice in connection with an acquisition and tax consequences related to capital investments.
• Advised global wealth managers on the tax consequences of a cross-border transaction with offshore trust structures.
• Advised investment management firms on the implementation of an offshore fund structure, as well as tax issues pertaining to the acquisition of interests across Africa.

• 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.