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Josua Loots

Associate | Johannesburg

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Is lawyer

Contact

T: +27 11 669 9613

E: josua.loots@bowmanslaw.com

Overview

Josua advises on South African income tax and international tax matters, including tax structuring for corporate transactions, mergers and acquisitions, and reorganisations, as well as tax compliance, share scheme structuring, and regulatory engagement with SARS.

He has supported senior practitioners on corporate and commercial tax mandates for both local and international clients, with experience spanning the full transaction lifecycle – from initial tax due diligence and structuring through to implementation and post-transaction advisory.

Experience

Jurisdictions worked in: South Africa
Languages fluent in: English, Afrikaans

Josua has advised:

  • On corporate group restructurings and reorganisations, including the preparation of transaction steps memoranda, diagrams, and implementation timelines.
  • On the tax implications of mergers, acquisitions, and disposals, including change of control analyses and post-transaction tax matters.
  • On the tax structuring of cross-border investment platforms, including inbound and outbound investment structuring and the tax treatment of holding vehicles.
  • On SARS binding private ruling applications across a range of transaction types and structures.
  • On exchange control matters, including the drafting and submission of SARB applications and engagement with authorised dealers.
  • On BEE and employee share incentive scheme transactions, including the drafting of notional vendor financing memoranda and tax analyses of incentive scheme structures.
  • On tax due diligence exercises in support of M&A transactions, including the identification of tax risks and structuring opportunities.

AREA OF EXPERTISE

Qualifications

Education

  • Bachelor of Commerce in Law (Taxation and Economics), University of Pretoria.
  • Bachelor of Law (cum laude), University of Pretoria.

Professional Memberships

  • Attorney of the High Court of South Africa
  • Member, Legal Practice Council of South Africa.

Overview

Josua advises on South African income tax and international tax matters, including tax structuring for corporate transactions, mergers and acquisitions, and reorganisations, as well as tax compliance, share scheme structuring, and regulatory engagement with SARS.

He has supported senior practitioners on corporate and commercial tax mandates for both local and international clients, with experience spanning the full transaction lifecycle – from initial tax due diligence and structuring through to implementation and post-transaction advisory.

Experience

Jurisdictions worked in: South Africa
Languages fluent in: English, Afrikaans

Josua has advised:

  • On corporate group restructurings and reorganisations, including the preparation of transaction steps memoranda, diagrams, and implementation timelines.
  • On the tax implications of mergers, acquisitions, and disposals, including change of control analyses and post-transaction tax matters.
  • On the tax structuring of cross-border investment platforms, including inbound and outbound investment structuring and the tax treatment of holding vehicles.
  • On SARS binding private ruling applications across a range of transaction types and structures.
  • On exchange control matters, including the drafting and submission of SARB applications and engagement with authorised dealers.
  • On BEE and employee share incentive scheme transactions, including the drafting of notional vendor financing memoranda and tax analyses of incentive scheme structures.
  • On tax due diligence exercises in support of M&A transactions, including the identification of tax risks and structuring opportunities.

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