Julia Choate

Julia Choate

Senior Associate
Cape Town, South Africa
T: +27 21 480 7863
E: julia.choate@bowmanslaw.com
  • Overview
  • Experience
  • Publications & Insights


Julia is a senior associate in our Cape Town office Tax Practice. She has a specific interest in tax dispute resolution and tax administration and has been involved in litigating and settling several large income tax and customs and excise disputes. Julia has a particular interest in the application of Constitutional and administrative law principles to tax administration and disputes.

Julia regularly advises on a wide range of tax issues for both South African and multinational groups, including types of acquisition funding, and the establishment of a business presence in South Africa. She also regularly advises on employee incentive schemes and analyses the tax consequences of such schemes.

Julia has an interest in customs and excise and Inter-African trade and has advised on aspects of the South African Customs Union (SACU) Agreement and the new African Continental Free Trade Agreement. Her clients include SABMiller/AB InBev, African Rainbow Minerals Ltd, Chevron Corporation, IMI Plc, Investec Asset Management, Massmart, CIVH, WACO International, and Marsh South Africa.

Julia has an LLB degree from the University of Cape Town, a Postgraduate Diploma in Tax (awarded with Distinction) from the University of Cape Town and a PhD in Tax Law (specializing in Tax Administration) conferred by the University of Cape Town in July 2022, under the supervision of Judge Dennis Davis and Dr Tracy Gutuza.

Specialist Services

Relevant Experience

Some of her experience includes:

  • tax counsel for the largest African brewery in various customs and excise disputes;
  • tax and customs and excise litigation counsel to various large mining ventures and energy corporations in the context of various diesel refund, customs, and fuel excise disputes;
  • tax counsel to one of Africa’s largest fiber-optic network operators in the design and implementation of a comprehensive employee incentive plan;
  • South African Tax Counsel advising Investec Asset Management on certain tax aspects of the unbundling and dual JSE and LSE listing of Ninety-One.
  • South African Tax Counsel advising Marsh & McLennan Companies, Inc. on the acquisition of Jardine Lloyd Thompson Group plc (USD 5.6 billion).

Julia regularly advises clients on a diverse range of issues, including:

  • managing income tax and indirect tax audits and interactions with the South African Revenue Service.
  • the application of the GAAR and “substance over form doctrine” to various transaction structures.
  • various matters involving the entitlement of a taxpayer to a tax deduction for interest and related expenditure.
  • various matters regarding the tax treatment of the sale and acquisition of debt securities and similar rights.
  • the meaning of the phrases ‘actually incurred’ and ‘not of a capital nature’ in the context of claiming deductions for expenditure.

Publications & Insights