Benjamin has advised: 

* experience gained prior to joining Bowmans

• Corporate entities (both local and foreign) on various cross-border corporate structuring transactions including, establishment of intermediary/investment holding companies, group re-organisations, funding considerations, withholdings tax considerations and tax treaty analysis.* 

• Corporate entities on various exchange control matters including inbound and outbound debt and equity funding, security and guarantee arrangements and share transfers.* 

• A global financial institution in relation to their loan funding facilities made available to certain South African companies and the withholding tax treatment of cash flows from South Africa.* 

• An international telecommunications company on its internal tax risk policy in relation to South Africa and dispute resolution process with the South African Revenue Authority.* 

• Rand Merchant Bank (a division of FirstRand Bank Ltd) on the preference share financing in respect of the 89MW Castle Wind Farm, the first private power deal to reach financial close for Sibanye-Stillwater, delivering power to its mining operations. The project consortium consists of African Infrastructure Investment Managers, through its renewable energy project development and delivery platform, African Clean Energy Developments and Reatile Renewables.* 

• Rand Merchant Bank (a division of FirstRand Bank Ltd) and a financial services group as joint mandated lead arrangers in respect of the financing of the 97.5MWac Solar PV Project and 140MW Wind Project developed by Mainstream Renewable Power Developments (Pty) Ltd for the generation and sale of energy to each of Sasol South Africa Ltd and Air Liquide Large Industries South Africa Proprietary Ltd.* 

• Solarpack in relation to the Energy Procurement Contract structure in South Africa and the most tax efficient means of funding the domestic operations.* 

• Zarclear Securities Lending (Pty) Ltd on the South African income tax and dividends tax implications of distributions received from real estate investment trusts.* 

• Magotteaux International S.A. on its acquisition of equity shares and a shareholder loan held by the Industrial Development Corporation of South Africa Ltd in Grinding Media South Africa (Pty) Ltd, as part of Magotteaux’s increased investment in Grinding Media.* 

• A global financial institution on the tax treatment of cash flows from South Africa to the said institution under the loan as a result of the USD 750 million loan facility provided to Eskom Holdings SOC Ltd.* 

• Thebe Investment Corporation on the ZAR 2.8 billion debt/preference share renewable energies refinancing transaction.* 

• iThokazi on the ZAR 310 million debt/ preference share refinancing transaction. iThokazi is one of South Africa’s largest 100 % black-owned renewable energy producers, created from the merger of four BEE entities.* 

• Community Investment Ventures Holdings and its affiliates on the acquisition by Vodacom of a controlling interest in Vumatel and DFA for ZAR 13.2 billion.* 

• Reunert Ltd (a JSE Listed company) and its associated entities on general tax matters.* 

• Royal Reesink, one of the world’s largest distributors of high-quality machinery, on the acquisition of all the issued shares of South African-based import and distribution company, Smith Mining Equipment Proprietary Ltd.* 

• KLL Group, Tongaat Hullett Ltd and Barloworld Ltd on the exchange control implications of the sale of Tongaat Hullet’s starch division (and in particular its foreign investments which formed a part thereof) to KLL Group.*  

• Azari Wind (Pty) Ltd on the tax considerations relating to its offshore expansion into Europe, particularly Finland and Sweden. Experiential Marketing (Pty) Ltd (and its underlying group of companies) on the group restructuring considerations as part of its BEE restructuring transaction.*  

• Investec Bank Ltd and Invictus Education Group (Pty) Ltd on the Invictus Group restructure and additional Investec preference share funding.* 

• Philafrica Foods Proprietary Ltd and Dutch Agricultural & Trading Company B.V on restructuring the offshore group structure to achieve a more commercially efficient structure.*