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Andrew Lewis


Andrew advises clients on the full range of commercial and financial law services with a particular focus on tax consultancy services (including corporate and international tax consulting, indirect tax, financial services tax, employee's taxes and dispute resolution). 
He advises clients on drafting tax opinions in most areas of tax law (but with a particular focus on local and foreign corporate restructurings), submitting advance tax ruling applications and voluntary disclosure applications, advising on different employee share incentive schemes, advising on tax dispute resolution matters, presenting to clients on recent developments in the tax field, drafting and commenting on various commercial agreements.

Professional QualificationsAttorney of the High Court of South Africa, 2010


  • Advising Allied Electronics on the estimated ZAR16 billion de-merger of Bytes UK, which was awarded Deal of Year on Ansandra Dealmakers Awards (2021).
  • Advising Community Investment Ventures Holdings on the proposed acquisition by the Vodacom Group of a 30% indirect stake in Vumatel and Dark Fibre Africa, in a deal valued at approximately R13.2 billion.
  • Advising Thebe Investment Corporation on the ZAR2.8 billion debt / preference share renewable energies refinancing transaction.
  • Advising warranty and indemnity (W&I) insurance brokers related to general W&I insurance policies as well as specific tax policies.
  • Engaging with the South African Revenue Service to obtain clarity on the new collateral arrangement dispensation which allows for the outright transfer of certain types of security without triggering tax consequences.
  • Drafting a number of binding class and private ruling applications including, BCR 20, BCR 21, BCR 23 and BPR 190 (Notional Funding Arrangement).
  • Providing tax advice on the debt instrument programmes established by various financial services groups.
  • Advising on various financial service related queries for equity linked note programmes and preference share arrangements.
  • Advising a foreign fund manager on the tax and exchange control implications of establishing a parallel private equity fund to invest in Sub-Saharan Africa. Approval was obtained from the SARB to establish the fund.
  • Assisting with the advance tax rulings submitted to SARS in respect of the demerger of companies as well as liaising with SARS and Computershare to facilitate the refund of dividend withholdings taxes imposed on South African resident depositary receipt holders.
  • Advising on the tax implications of and implementation of a number of black economic empowerment transactions, including the implementation of the notional vendor funding structures.
  • Advising on the tax implications of and implementation of share incentive schemes.
  • Advising clients on the tax implications and commercial considerations in relation to the royalty agreements, technical services and information systems divisions services agreement and buying-agency agreements.
  • English
  • University of Witwatersrand, Advanced Company Law I & II, 2013
  • University of Johannesburg, Higher Diploma in Tax Law, 2007
  • University of Johannesburg, LLB, 2005

    University of Johannesburg, BCom Law, Majors in Economics and Law, Bachelor of Commerce, 2003


  • The Legal 500 EMEA 2023 recommended Andrew for tax
  • Nominated in Thomson Reuters Stand-Out Lawyer category for outstanding client service (2023)


  • The perennial struggle between SARS, tax consultants and aggressive tax schemes, 8 Jun 2018
  • South Africa: Roll-over relief for intra-group disposal of a capital asset, 23 Apr 2018
  • South Africa Legal agreements influence transfer duty liabilities, 23 Apr 2018
  • South Africa: Legal agreements influence transfer duty liabilities, 18 Apr 2018
  • Key Take-Aways From The South African National Budget Speech 2018, 23 Feb 2018
  • Dutch court confirms dividend withholding tax exemption under the treaty between South Africa and the Netherlands, 5 Feb 2018
  • Latest tax legislation makes for interesting reading, 15 Nov 2017
  • South African Revenue Service scrutinizes taxable presence of foreign service providers in South Africa, 1 Nov 2017
  • Silke on International Tax, 2010 LexisNexis (available electronically) - Co-authored the chapter, "Jurisdiction to Tax", with Professor Alwyn de Koker and authored the chapter on "Residence" from a South African and International Tax perspective
  • Business Brief, Business Day, Without Prejudice, Die Berger, Cliffe Dekker Hofmeyr weekly Tax Alerts - Some of the titles of my more recent articles include the following:
    • "Notional Funding Arrangements" - relating to the Binding Private Ruling No. 190 I obtained on behalf of a client
    • "Contentious International Corporate Restructuring Ruling" - discussing SARS' BPR 178 on the application of section 42 and 45 to an international corporate restructuring
    • "Notion of piercing the corporate veil has been extended" - discussing the application of Ex parte application of Stephen Malcolm Gore No.O and 37 Others N.N.O (Case No: 18127/2012), Western Cape High Court in a tax and company law context


Presenting at the JSE for the Bank of New York and the top forty listed companies on the new dividend withholdings tax introduced with effect from 1 April 2012.