Robyn Berger

Robyn Berger

Executive - Tax
Johannesburg, South Africa
T: +27 11 669 9301
  • Overview
  • Experience
  • Publications & Insights


Robyn Berger is a Tax Executive in our Corporate Department and is a member of our Johannesburg office Tax Practice.

Robyn specialises in cross-border tax and exchange control implications of both outbound and inbound investments, with a keen focus on African investments.

Her client base is expansive, thereby affording her broad industry knowledge ranging from private equity, fintech, consumer markets, energy and natural resources, engineering, financial services, hospitality, insurance and retail sectors.  

Robyn’s qualifications include a BCom in Financial Accounting from the University of South Africa, as well as Higher Diplomas in Taxation and in International Taxation, from the Rand Afrikaans University (now University of Johannesburg).

Specialist Services

Relevant Experience

Having previously led the International Tax team at one of the Big Four auditing firms, Robyn has a broad set of technical skills in the corporate tax, international tax and exchange control space, including the following:

  • assisting multinationals investing into South Africa, whether through a new operational set-up or through the acquisition of a target entity;
  • assisting South African multinationals with the tax and exchange control implications arising from outbound investments. This includes advice pertaining to the appropriate ownership structure, tax residency of foreign entities; the implications of South African controlled foreign companies (CFC) legislation; double tax agreements; the claiming of foreign tax credits; the foreign tax jurisdictions tax regime; thin capitalisation; and transfer pricing constraints;
  • Advising on the establishment of private equity funds and the acquisition of target portfolio companies. Robyn’s experience ranges from fund set up to due diligence work, exchange control advice and applications and structuring of the acquisition;
  • leading general due diligence projects and internal restructure projects, with a significant focus on due diligence projects across several African countries;
  • advising clients both in South Africa and further afield (across Europe, Asia, Australasia and Africa) on the tax and exchange control implications of mergers and acquisitions;
  • assisting clients with SARS interactions – responding to queries for information as well addressing SARS’ findings of audits (these matters have extended to CFC queries, place of effective management queries (ie tax residence disputes) and the claiming of foreign tax credits);
  • leading tax dispute resolution matters in various African jurisdictions including Swaziland, Tanzania and Zambia;
  • advising on several transfer pricing projects;
  • Robyn is a member of the SAICA exchange control committee that meets with the South African Reserve Bank on a quarterly basis to discuss relevant exchange control developments.
  • Robyn is a member of the SAIT international tax committee.

Publications & Insights