Africa

Tax & TP Disputes and Litigation

Strategic readiness, not reactive defence.

Tax disputes are no longer rare events. Across Africa and South Africa, tax authorities are increasing scrutiny, particularly in transfer pricing and cross-border structures.

When disputes arise, most businesses are forced to coordinate between multiple advisors. We take a different approach.

Regan van Rooy brings together tax expertise and senior litigation capability in one integrated team to manage disputes from audit through to resolution. A first-of-its-kind integrated tax and litigation offering in South Africa.

The Reality of Tax Disputes

Tax disputes typically arise when:

Tax authorities challenge transfer pricing arrangements

Cross-border transactions are reassessed

Documentation is considered insufficient

Positions taken in returns are disputed

These situations escalate quickly. What starts as an audit can become a prolonged and costly dispute if not managed strategically from the outset.

The key difference is not whether a dispute happens, but how early and how well it is managed.

A Fully Integrated Approach

Most firms operate in silos:

  • Tax advisors manage technical arguments
  • Legal counsel is introduced later, often too late


Our model integrates both from the start.

You work with:

  • Senior tax and transfer pricing specialists
  • Experienced litigation counsel
  • A coordinated team managing the entire process


One strategy. One team. One outcome.

The Dispute Lifecycle

We support clients across every stage:

Risk Identification


Identifying exposure before it becomes a dispute

Audit Engagement


Managing interactions with tax authorities strategically

Dispute Escalation

Structuring arguments and managing risk

Litigation Strategy


Preparing for and supporting formal proceedings

Resolution

Achieving commercially effective outcomes

Our focus is proactive strategy, not reactive defence.

Our Services

We provide a comprehensive tax disputes and litigation offering:

Pan-African Capability

We support clients across Africa, including:

South Africa | Kenya | Nigeria | Mauritius | Zimbabwe | Zambia | Botswana | Namibia | Uganda | Ghana | Tanzania | Malawi

We provide consistent, coordinated dispute strategies across jurisdictions.

Our Team

For the first time in South Africa, tax advisory and litigation expertise sit under one roof. Together, our team has over 100 years of combined experience managing complex disputes across Africa.

Caoilfhionn van der Walt

Founder & Managing Partner

Cabrini McCarrick

Transfer Pricing Partner

Dr Daniel N Erasmus

Senior Tax Litigation Specialist

Russell Eastaugh

Head of African Tax

Rajnish Singh

Transfer Pricing Director

Tuli Nkonki

Transfer Pricing Associate Director

Dr Daniel N Erasmus participates as an independent senior tax counsel.

Selected Experience

Our approach is grounded in real dispute experience across Africa and internationally.

Examples include:

  • Reduction of a multi-billion rand transfer pricing exposure by more than 85% through structured dispute engagement
  • Successful resolution of disputes through alternative dispute mechanisms
  • Representation and support in complex transfer pricing litigation matters
  • Cross-border dispute coordination involving multiple tax authorities


We focus on outcomes, not theory.

Insights & Resources

We regularly share practical insights on:

The South African tax dispute environment

Transfer pricing audit triggers

Trends across African tax authorities

Tax Administration Act developments

Advance Pricing Agreements (APA)

Lessons from real disputes

Download 'Transfer Pricing on Trial' by Dr Daniel N Erasmus

A practical look at real-world transfer pricing disputes, based on litigation experience.

Work With Us

If you are facing a tax audit or dispute, concerned about transfer pricing exposure, expanding across Africa or looking to proactively manage tax risk, we can support you.

How prepared is your business for a tax dispute?

Take our free, 2-minute assessment and find out where your gaps are before a dispute finds them first.

Complete the fields below to download the guide by Dr Daniel N Erasmus.

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Book a meeting with our Transfer Pricing team by completing the form below.

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Thank you for your interest, please complete the form below to download the checklist pdf.

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Thank you for your interest, please complete the form below to download the full pdf.

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