Samir Ellary

Samir Ellary

Johannesburg, South Africa
T: +27 11 669 9338
  • Overview
  • Experience
  • Publications & Insights


Samir Ellary is a partner in the Tax Practice of our Johannesburg office and has over 13 years’ experience in Tax.

He specialises in all aspects of corporate taxation. His expertise extends to advising on mergers and acquisitions, employee share schemes, corporate restructurings, charitable trusts and cross-border transactions.

He particularly enjoys advising on the structuring and implementation of black economic empowerment transactions and the establishment of ‘BEE trust’ vehicles, where he has been involved in a number of large BEE transactions.

Samir is currently focusing on servicing a number of small to medium sized funds in the private equity space. He is also the lead tax partner for the South African tax practice for one of the world’s largest advertising and marketing groups.

Specialist Services

Relevant Experience

  • Part of team that assisted and advised Harmony Gold Mining Limited on its acquisition of AngloGold Ashanti Limited’s remaining operating assets in South Africa.
  • Assisted PPC Limited with the ‘clean-out’ of its historic broad-based black economic (BEE) transaction and with the establishment of a BEE Employee Trust (ESOP).
  • Assisted Standard Bank with the drafting and implementation of the “Feenix Fund”, a trust established in order to address some of the issues that arose through the “fees must fall” movement.
  • Assisted BASF South Africa with the establishment of a broad-based ownership scheme trust (BBOS) as part of BASF’s BEE ownership transaction.
  • Assisted Macmillan South Africa in a BEE transaction with the establishment of a BEE ESOP Trust.
  • Assisted Cisco South Africa in its restructuring of its BEE ownership and helped with amending the BEE ESOP for this purpose.
  • Assisted Alexander Forbes in its implementation of a BEE transaction involving the establishment of a BEE ESOP Trust.
  • Assisted SAB with the drafting of a commercial trust deed specific for some of their corporate customers which manages a discount/trade structure which ultimately served to provide more favorable terms of trade to those customers who settled their invoices early.
  • Advised the Intercontinental Hotels Group on aspects pertaining to their South African tax structure.
  • Advised and assisted Delta Property Fund with the establishment of a BEE ESOP.
  • Advised and assisted the ETEX group of companies with various exchange control approvals relating to their group debt restructuring and acquisition of business interests in South Africa.
  • Advised TransUnion LLC in relation to the South African tax and exchange control aspects pertaining to its global roll out of its employee stock purchase plan and assisted with the implementation of the plan in South Africa.

Publications & Insights