Newly Admitted Attorney - Ledwaba Mazwai Attorneys
(2023-03)
Litigation and tax related matters including cases involving SARS, capital gains tax assessments, VAT compliance, and corporate commercial projects including Public Private Partnership projects.
- Sasol Chevron Holdings Ltd ("Sasol") v Commissioner for Revenue Service ("CSARS") – Involved in the Team that assisted CSARS on the matter. Sasol took the case all the way to the CC where it sought interpretation of section 7(1) of PAJA and Regulations to section 74(1) of VAT Act. CSARS won the case with costs.
- City of Matlosana v Eskom Holdings SOC Ltd ("Eskom") – LM assisted Eskom with ligation against City of Matlosana for outstanding municipal debts. There were several orders granted in favour of Eskom. The City of Matlosana attempted to fight the orders using several urgent applications. Eskom won all litigation from 2021 to 2023 with costs.
- Josias Andries Agenbach NO and Others ("the Trust") v CSARS: Review Application – LM assisted CSARS in litigating the review of the Capital Gains Tax assessments raised by CSARS where the trust had ceased its residence in RSA to Namibia and expatriated some assets through a forward sale agreement in the region of R671m. CSARS won the review application with costs.
- Josias Andries Agenbach NO and Others ("the Trust") v CSARS: Repatriation Order – Following the success of the above application, CSARS then instructed LM to assist with the repatriation of the assets concerned. The case is still pending as CSARS is in the process of communicating with the Namibian Revenue Authorities.
- EOH Abantu (Pty) Ltd v CSARS ("EOH") – After much engagement on the issues of law, where EOH was disputing that it had evaded tax by structuring its employees' salaries with a "salary sacrifice" scheme. The litigation process had begun and pleadings exchanged. Just before exchange of Heads of Arguments, the parties reached a settlement and by 1 March 2024 EOH would pay SARS R112m.
- Vendcorp 54 CC ("Vendcorp") v CSARS – Vendcorp launched a review application against CSARS for refusing to grant Vendcorp Voluntary Disclosure relief. As of May 2025, the case is in the Supreme Court of Appeal where SARS is challenging the entire decision of the High court. CSARS has since been successful in its application for leave to appeal to the SCA.
- Char Trade 246 CC ("Char Trade") v CSARS - Char Trade launched a review application against CSARS for refusing to grant Char Trade Voluntary Disclosure relief. As of May 2025, the case has been pended by mutual agreement between the parties until the Vendcorp case has been finalised.
- CSARS v J Sassin and 13 Others – CSARS had conducted a tax audit because the taxpayer was suspected to have been committing serious tax offenses. It was discovered that the taxpayer was involved in activities where VAT fraud was involved. The matter is now at Discovery Stage. As of March 2025, the parties have entered a settlement.
- Estate Late Papo – Brought on the case in about July 2025 onto a case that had gone on since 2017. Managed to assist the Executors with submission of the required documentation and secure a refund due to the Estate.
- MN Sontsele Property Investments (Pty) Ltd – Leading the Team that is responsible for restructuring the Shareholder's assets into the company using section 42 of the Income Tax Act.
- Royal Bafokeng Holdings (RBH) – Part of the lead team that is assisting RBH to acquire a stake in Afrihost. Responsible for the tax consequences of the transaction.
Newly Admitted Attorney - Ledwaba Mazwai Attorneys
(2023-03)
Public Private Partnership projects
- Inkosi Albert Luthuli Care Hospital – Part of the LM Team that is assisting the Department of Health KZN to negotiate PPPA Bid Window 2 that will build and operate the hospital for a period of 12 years. Involved in attending weekly TA meetings and meetings with the preferred bidder. Commercial close for the projects was reached on 31 May 2024.
- Department of Public Works and Infrastructure ("the Department") – Part of the LM Team that is assisting the Department with putting together the Integrated Renewable Energy and Resource Efficiency Programme ("iREREP"). iREREP is in Bid Window 1 and at the stage where the optimised RFP has been issued to market. Form part of the Legal Team that will be evaluating the bids. As of November 2025, the Department had put on hold the evaluation of bids due to the Department's internal logistics.
- City of Cape Town Sea Water Desalination – Part of the LM Team that is assisting the City of Cape Town with the desalination of sea water from feasibility to appointment of bidder. The project is at feasibility stage. As of October 2025, the Public comments had been processed and incorporated into the Feasibility Study Report.
- Gauteng Province Economic Development: Automotive Industry Development Centre ("AIDC") Inland Port – Part of the LM Team that is assisting AIDC with feasibility study to appointment of bidder to construct and operate an inland port in the Pretoria Rosslyn. As of November 2025, the Feasibility Study had been submitted to the client.
Newly Admitted Attorney - Ledwaba Mazwai Attorneys
(2023-03)
Other Projects
- Independent Power Producers (Department of Energy) – Involved in legal evaluation part of the legal component of the bids for three bid windows for Battery Storage.
- Government Technical and Advisory Centre ("GTAC") – Part of LM Team that is currently assisting National Treasury ("NT") with drafting of amendments to the PPP legislation in all three spheres of government. The project involves implementation of recommendations of an independent review that was done in 2019 and reported in 2021 for NT. As of November 2024, the amendments NTR16 were signed into law.
- Eskom Holdings SOC Ltd – Part of Legal Team that advises Eskom on a transaction for developing Solar and Wind Power Plants through private sector participation.
Chief Tax Advisor dealing with advisory, compliance and planning - Eskom Holdings SOC Ltd (Eskom)
(2010-08 - 2023-02)
Worked mainly with tax policy and advisory, involved in liaising with SARS and National Treasury as external tax stake holders (administratively and regulatory). Responsible for tax planning and compliance by mainly reviewing contracts that Eskom entered into with foreign and local suppliers and various tax returns before submission to SARS. Also responsible for training business units with day-to-day tax compliance matters, like capturing of transactions into the financial system in a correct manner that complied with taxes at Eskom Holdings.
- Responsible for compliance, planning and advisory for corporate, VAT and employment taxes.
- Contract review for tax implications prior to sign-off.
- Provided tax (VAT, PAYE) training to business units.
- Liaison with SARS and National Treasury in relation to legislative tax matters that affected Eskom.
- Compilation of Process Documents (Process Control Manuals).
- Responsible for CbC reporting and cross border tax advisory.
- Responsible for reviewing corporate, PAYE and VAT tax returns before submission to SARS.
Senior Tax advisor dealing with Corporate Tax and VAT - Eskom Enterprises SOC (Pty) Ltd
(2006-04 - 2010-07)
Worked as a Senior Tax Advisor for the four subsidiary companies of Eskom Holdings that existed at the time and was solely responsible for direct and indirect taxes for them.
Senior Tax Officer: Integrated Audits - SARS (National Enforcement Unit)
(2002-09 - 2004-06)
- Investigated and performed of integrated tax audits.
- Taxpayer liaison.
- Drafted Interpretation Notes, Tax brochures and booklets.
- Issued rulings and opinions specifically in capital allowances.
- Liaison with National Treasury about amendments in direct taxes.
SARS (Head Office): Tax Policy Administration - SARS (Head Office)
(2004-07 - 2006-03)
Tax Consultant - PWC
(2001-01 - 2002-08)
- Rendered tax advice to various corporate clients in the Financial Services unit.
- Tax advisor for high net-worth individuals.
- Liaison with SARS on behalf of clients.
Tax Officer (Assessments and audits) - SARS
(1997-06 - 2000-12)
- Assessment of individuals, companies and farmers.
- Auditing of refunds and handling of objections.
- Provided general taxpayer service.
Data capturing (transactional banking) - Standard Bank
(1996-10 - 1997-05)
- Captured daily paper banking transactions into the bank's computer system.
