Lebo Motsumi-Nkoloti

Lebo Motsumi-Nkoloti

Senior Associate
Johannesburg, South Africa
T: +27 11 669 9409
E: lebo.motsumi@bowmanslaw.com
  • Overview
  • Experience
  • Publications & Insights


Lebo has a keen interest in tax dispute resolution and has experience in litigating and settling tax disputes across all tax types.  Lebo regularly engages with SARS on behalf of clients and plays a key role in the resolution of disputes with SARS. As part of her practice, Lebo also assists clients with developing and implementing procedures which assist clients to proactively manage the risks related to complying with tax requirements.


  • Bachelor of Arts, Rhodes University
  • Bachelor of Laws, Rhodes University
  • Master of Laws: Commercial Law, University of Cape Town
  • Higher Diploma in International Tax, University of Johannesburg
  • Master of Commerce: South African and International Tax, University of Johannesburg

Professional Memberships

  • Admitted attorney of the High Court of South Africa.
  • Member of the SAIT Customs and Excise Technical Work Group.

Specialist Services

Relevant Experience

Lebo’s recent experience includes:

  • Advising a Johannesburg Stock Exchange listed mine on the potential application of the specific anti-avoidance rules pertaining to “hybrid equity instruments” and “third-party backed shares” on a broad-based black economic environment transaction.
  • Representing various corporate taxpayers in relation to tax disputes against the revenue authority across the various tax types (income tax recoupments, deductions from output tax, customs and excise, deductibility of expenses, etc).
  • Advising a software, instrument and equipment supplier on the income tax implications of the embezzlement of funds by an employee and drafting and submitting an application for voluntary disclosure relief in respect of the input tax deductions erroneously made as a result of the fraudulent transactions.
  • Providing international tax / structuring advice in relation to an investment into a New York Stock Exchange listed special purpose acquisition company.
  • Representing a client on a circa ZAR 700 million tax dispute relating to the alleged underpayment of customs duties.
  • Advising prominent bank on the tax implications of a demerger and public listing on the London and Johannesburg Stock Exchange.
  • Representing a client on a circa ZAR 35 billion tax dispute in relation to a transaction attacked by the revenue authority in terms of the substance over from principles.
  • Advising major brewery on the tax implications of various long-term share incentive plans granted to various executives.
  • Advising a global consulting service provider funded by a foreign government on the value-added tax and exchange control implications of winding up the South African activities of the “foreign donor funded project” in South Africa.

Publications & Insights