Tax Dispute Methodology

“We pride ourselves in giving the highest degree of professional service to individuals, businesses, corporations, and MNEs (together with their usual advisors) on domestic and international planning, tax audit and tax litigation issues.

Our successful methodology has produced remarkable results. Just under USD$4bn tax exposures have resulted in less than 3% tax liabilities for clients.”

Despite our many successes in tax court, we DO NOT go to court often. We usually settle most matters favourably for clients out of court. But when we do go to tax court, our team is well experienced in preparing for, and arguing tax trials in many African jurisdictions.

Dr. Daniel N. Erasmus has argued at tax trials in South Africa, Zimbabwe, Tanzania, Uganda and Mauritius, with tax trials pending in Malawi. Due to his specialized expertise and experience, he is given special permission to appear in court in these different jurisdictions.

Our Successes

  • Ghana – transfer pricing in property industry and management fees and financing – settled at tax audit;
  • Hungary – tax risk management process for MNE based world-wide reducing in excess of US$20m in historic tax exposures;
  • Ireland/Africa – compile Africa-wide transfer pricing studies
  • Malawi – USD$43m – transfer pricing;
  • Malawi – USD$1m Mining industry WHT & VAT – settled, no tax liability after presentations to MRA;
  • Mauritius/Africa – compile Africa-wide transfer pricing studies;
  • Mauritius – USD$ 200m interest and capex deductions – awaiting judgment;
  • Nigeria – review MNE transfer pricing studies;
  • Romania – tax risk management process for MNE based world-wide reducing in excess of US$20m in historic tax exposures;
  • Rwanda  – USD$ approx. 12m – transfer pricing & VAT;
  • South Africa – USD$400m – transfer pricing royalty charges – MNE operations in Africa, Asia, Middle-East and Europe – trial postponed;
  • South Africa – USD$80m – transfer pricing royalty charges/legal & economic ownership;
  • South Africa – USD$60m – customs/excise – liquor industry classification dispute;
  • South Africa – USD10m – SARS back-dating revised assessment;
  • South Africa – USD$30m – VAT apportionment of input tax credits;
  • South Africa – search & seizure warrant & tax audit/investigation;
  • South Africa/Africa – compile Africa-wide transfer pricing studies;
  • South Africa – tax risk management process for MNE based world-wide reducing in excess of US$300m in historic tax exposures;
  • South Africa – Mining house tax audit settled due to prescription – USD$100m revised tax assessment eliminated;
  • South Africa – historic judgment that without a letter of findings SARS cannot issue revised assessments;
  • South Africa – secrecy provisions applicable to tax audits & court orders sought by SARS – ongoing;
  • Tanzania – USD$ 20m PE issues in technology industry – judgment in favour of client;
  • Tanzania – USD$ 15m transfer pricing exposure for contract manufacturer – judgment in favour of client;
  • Uganda – USD$54m – transfer pricing management fees & capital v revenue deductions – mediation in favour of client;
  • US – USD$30m – advice on no tax residency in US to eliminate exit tax;
  • US – advice on no tax residency in US for CEO of UAE royal family-owned operation;
  • US – advice & representation on late FBAR filings and IRS Offshore Voluntary Disclosure Program;
  • US – advice to US tax practitioners as specialist on OIC, EITC, late FBAR/PFIC/Form 5471/Form 8840 filings;
  • US – tax court petitions – failure to file/arrear taxes – Canadian doctor & citizen;
  • US – advice on tax court petition – Schedule C landscaping business deductions;
  • US/Africa – USD$100m – advice & structuring on foreign trust/corporation connection to US/Africa tax resident, receiving gift;
  • US/Africa – disinvestment from Africa operations – tax implications – controversy International Tax & State Responsibility relief;
  • Zambia – USD$55m – exit tax/lien – settled;
  • Zambia  – USD$approx. 10m – transfer pricing dispute in the manufacturing sector – settled;
  • Zimbabwe – USD$20m – transfer pricing agricultural industry – on appeal (then abandoned due to currency conversion from USD$);
  • Zimbabwe – USD$ extensive, being calculated for 21 subsidiaries – Management fees for large conglomerate – on appeal;
  • Zimbabwe – USD$5m Tobacco industry VAT – on appeal (then abandoned due to currency conversion from USD$).
  • …and more!

Mastering Tax Dispute Resolution: Our Strategies

by Prof Dr. Daniel N. Erasmus

A Strategic Approach

Navigating the complexities of tax disputes requires expertise and a strategic approach. At, led by Prof. Dr. Daniel N. Erasmus, we specialize in Tax Dispute Resolution. Our methodology, refined over years of successful engagements, emphasizes early intervention and comprehensive preparation, offering unparalleled expertise in resolving tax controversies before they escalate.

Intricate Journey

The journey of resolving tax disputes is intricate, demanding a nuanced understanding of both local and international tax laws. Our approach is to engage at the audit stage, navigating through the letter of findings and, if necessary, representing clients in tax courts with a success rate that speaks volumes about our expertise.

Our successes detailed above span various jurisdictions where we have significantly reduced tax liabilities and, in many instances, achieved a nil tax liability for our clients. This success stems from our ability to effectively argue and present evidence as if in tax court from the audit stage, convincing tax authorities of our stance.

Furthermore, our affiliations with professional tax firms and our internal team of consultants underscore our commitment to excellence and results.

How my team can assist:

Our team are pioneers in Tax Dispute Resolution, offering unmatched expertise and a proven track record of success. Their approach, focusing on early intervention, detailed preparation, and strategic representation, has saved clients billions by minimizing tax liabilities.

With a global network of professional affiliations and a team skilled in both local and international tax laws, they ensure clients are well-positioned to overcome the challenges of tax disputes. Whether it’s navigating audits, the letter of findings process, or representation in tax courts, their methodology is designed to protect client’s interests effectively and efficiently.

Download the full Tax Dispute Methodology document here>>>