Wally Horak
Head of Tax, Cape Town | Cape Town
Contact
T: +27 21 480 7935
E: wally.horak@bowmanslaw.com
Overview
Wally uses his encyclopedic knowledge of the law to answer his clients’ most complicated tax questions. He provides solutions that are both technically astute and commercially focused to make sure they deliver real business benefits.
He has a focus on cross-border M&A, financing, transfer pricing, exchange control, international share incentive schemes and expatriate secondments. He is particularly known for developing tax-efficient structures to help investment both into and out of South Africa, advising private equity funds, VCs and large corporates. He uses his years of experience to deliver practical solutions to clients.
He has particular knowledge of advising international investors in the renewables sector, where his experience with international tax issues is helping clients unlock green investments. He also regularly advises US private equity funds on their investments into mining in Africa, in particular their mine finance ventures.
He delivers quick responses to complicated problems, all explained in a practical and easy-to-understand way.
Professional Memberships
- Member of the South African Fiscal Association, Tax Practitioner No PR-2216D5F
Experience
Languages Fluent in: English, Afrikaans and German
- Advice to Old Mutual Hybrid Equity Fund 1 re the tax treatment of preference share funding
- Advice to Coronation on tax dispute
- Advice to African Rainbow Capital re tax implications of preference share funding arrangements
- Advising Alexander Forbes on the tax implications of its foreign operations
- Advising Climate Fund Managers on their investments into renewable energy projects
- Advice to Orion on tax implications of funding arrangements with South African mines
- Advising Mpilo/Mediclinic on a tax dispute
- Advising venture capital funds on tax implications of Naspers/Prosus share restructure
- Advice to Sanlam on tax implications of cross border transactions
- Advice to Ethos on the tax implications of fund structures
- Advice to the Jumo Group on tax implications of mobile banking operations in various African countries
- Advising ABinBEV on tax implications of cross border funding arrangements
Awards
- Chambers Global ranked Wally as ‘Senior Statespeople’ for his work in Tax in 2024.
- Ranked by Legal 500 as a Leading Individual for Tax for six consecutive years (2017 to 2022) and prior to that in Tier 1 for the same category in 2015.
- Wally was recognised by Who’s Who Legal 2018 in the following categories: Corporate Tax: Advisory; Private Client: Lawyers; and Corporate Tax: Controversy.
‘Wally Horak is a very good international tax practitioner.’ – Chambers and Partners, 2024
AREA OF EXPERTISE
Qualifications
- BA-Law, Stellenbosch.
- LLB, Stellenbosch.
- LLM, Stellenbosch (research at University of Munich).
- HDIP Tax Law, University of the Witwatersrand.
INSIGHTS
South Africa: National Budget Speech 2024 – tax takeaways within the private equity context
South Africa: New reporting requirements regarding beneficial ownership in relation to trusts
South Africa: An overview of SARS’ Interpretation Note 127
(Over)taxing loop structures in South Africa
Amending preference share terms without triggering tax
South Africa – Unilateral measure considered to tax digital economy
Update on grandfathering problems for venture capital companies
Update on the application of the most favoured nation clause in the South Africa and Netherlands tax treaty
Tax Court upholds most favoured nation clause in South Africa and Netherlands tax treaty
The impact of changes to the permanent establishment principle
Budget 2018: Important proposed changes for businesses
South African National Budget Speech 2018
Transfer pricing audits put the squeeze on in Africa
Transfer pricing a critical issue for African tax administrations
Brochures
Press Release & Announcement
Overview
Wally uses his encyclopedic knowledge of the law to answer his clients’ most complicated tax questions. He provides solutions that are both technically astute and commercially focused to make sure they deliver real business benefits.
He has a focus on cross-border M&A, financing, transfer pricing, exchange control, international share incentive schemes and expatriate secondments. He is particularly known for developing tax-efficient structures to help investment both into and out of South Africa, advising private equity funds, VCs and large corporates. He uses his years of experience to deliver practical solutions to clients.
He has particular knowledge of advising international investors in the renewables sector, where his experience with international tax issues is helping clients unlock green investments. He also regularly advises US private equity funds on their investments into mining in Africa, in particular their mine finance ventures.
He delivers quick responses to complicated problems, all explained in a practical and easy-to-understand way.
Professional Memberships
- Member of the South African Fiscal Association, Tax Practitioner No PR-2216D5F
Experience
Languages Fluent in: English, Afrikaans and German
- Advice to Old Mutual Hybrid Equity Fund 1 re the tax treatment of preference share funding
- Advice to Coronation on tax dispute
- Advice to African Rainbow Capital re tax implications of preference share funding arrangements
- Advising Alexander Forbes on the tax implications of its foreign operations
- Advising Climate Fund Managers on their investments into renewable energy projects
- Advice to Orion on tax implications of funding arrangements with South African mines
- Advising Mpilo/Mediclinic on a tax dispute
- Advising venture capital funds on tax implications of Naspers/Prosus share restructure
- Advice to Sanlam on tax implications of cross border transactions
- Advice to Ethos on the tax implications of fund structures
- Advice to the Jumo Group on tax implications of mobile banking operations in various African countries
- Advising ABinBEV on tax implications of cross border funding arrangements
Awards
- Chambers Global ranked Wally as ‘Senior Statespeople’ for his work in Tax in 2024.
- Ranked by Legal 500 as a Leading Individual for Tax for six consecutive years (2017 to 2022) and prior to that in Tier 1 for the same category in 2015.
- Wally was recognised by Who’s Who Legal 2018 in the following categories: Corporate Tax: Advisory; Private Client: Lawyers; and Corporate Tax: Controversy.
‘Wally Horak is a very good international tax practitioner.’ – Chambers and Partners, 2024
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