Diwan Kamoetie
Senior Associate | Johannesburg
Contact
T: +27 11 669 9481
Overview
Diwan regularly advises on domestic and international investment and ownership transactions, including equity financing, debt financing, B-BBEE transactions, transfer pricing, and exchange control. Diwan also has experience advising on advises on the taxation of structured financial products, the application of the corporate roll-over relief provisions, the tax implications in M&A transactions, and customs and excise.
Experience
* Includes experience gained prior to joining Bowmans
Diwan has advised clients on the following tax issues:
- Infinite Partners, Convergence Partners, Nedbank Private Equity, Bud Group, Boardriders group, and RMB Ventures 9 in respect of acquisitions and disposals.
- Restructuring of the ownership structures of MPact Polymers.
- Local and cross-border merger and acquisition transactions, and other acquisition transactions that required post-acquisition integration restructuring.
- The restructuring of local and cross-border intra-group transaction, which includes the restructuring of intra-group debt.
- The introduction of black economic empowerment, through notional vendor funding.
- Advising on numerous Domestic Medium Term Note Programmes, and ancillary debt offering documents.
- The exchange control implications of both outbound and inbound investments.
- The implications of retroactive transfer pricing adjustments on customs valuations.*
- Obtaining value determination numbers in terms of the Customs and Excise Act, 91 of 1964.*
- Customs and excise disputes with SARS.*
Awards
- Legal 500 ranked Diwan as a Leading Associate for Tax in South Africa (2026).
AREA OF EXPERTISE
Qualifications
Education
- Master of Commerce (Accounting, Taxation) (cum laude), University of Witwatersrand.
- BAcc and LLB degrees, University of Stellenbosch.
INSIGHTS
Overview
Diwan regularly advises on domestic and international investment and ownership transactions, including equity financing, debt financing, B-BBEE transactions, transfer pricing, and exchange control. Diwan also has experience advising on advises on the taxation of structured financial products, the application of the corporate roll-over relief provisions, the tax implications in M&A transactions, and customs and excise.
Experience
* Includes experience gained prior to joining Bowmans
Diwan has advised clients on the following tax issues:
- Infinite Partners, Convergence Partners, Nedbank Private Equity, Bud Group, Boardriders group, and RMB Ventures 9 in respect of acquisitions and disposals.
- Restructuring of the ownership structures of MPact Polymers.
- Local and cross-border merger and acquisition transactions, and other acquisition transactions that required post-acquisition integration restructuring.
- The restructuring of local and cross-border intra-group transaction, which includes the restructuring of intra-group debt.
- The introduction of black economic empowerment, through notional vendor funding.
- Advising on numerous Domestic Medium Term Note Programmes, and ancillary debt offering documents.
- The exchange control implications of both outbound and inbound investments.
- The implications of retroactive transfer pricing adjustments on customs valuations.*
- Obtaining value determination numbers in terms of the Customs and Excise Act, 91 of 1964.*
- Customs and excise disputes with SARS.*
Awards
- Legal 500 ranked Diwan as a Leading Associate for Tax in South Africa (2026).
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