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Photo, Denny Da Silva

Denny Da Silva

Senior Tax Advisor
Baker & McKenzie

Biography

Denny Da Silva is a senior tax advisor and director designate in Baker McKenzie's Tax Practice Group in Johannesburg. He has more than 16 years' experience in both domestic and international corporate tax, as well as in the application of exchange control regulations. He also has experience in tax due diligence, corporate restructurings, mining transactions, private equity fund structures, management carry structures, black economic empowerment, transfer pricing and employee's tax.

Denny also guest lectures at the University of Johannesburg's MCom Tax programme.

Representative Legal Matters

  • Advised an electricity utility company of the direct tax implications in relation to its acquisition of Xina Solar One.
  • Advised EPC Fund on the direct and indirect tax implications in relation to its acquisition of an American-based multinational chain of hamburger fast-food restaurants.
  • Advised a holding company in the platinum industry of the direct tax implications in respect of the investment into AP Ventures Fund II.
  • Advised a multinational manufacturer and marketer of home appliances and assisted with a transfer pricing audit by the South African tax authority.
  • Advised a multinational company in the internet sector on the tax considerations relevant for its establishment of its South African structure.
  • Provided tax dispute resolution assistance to client in respect of employment tax incentive.
  • Provided tax advise to an international client in respect of the establishment of a carbon credit generating business and the trading of carbon credits.

Professional Associations and Memberships

  • South African Institute of Tax Practitioners

Education

  • International Bureau of Fiscal Documentation IBFD (Transfer Pricing Certificate) (2022)
  • South African Institute of Tax Practitioners (Chartered Tax Practitioner) (2022)
  • University of Johannesburg (LL.M. Corporate Law) (2014)
  • University of Johannesburg (Higher Diploma International Tax Law) (2008)
  • University of Johannesburg (Higher Diploma Tax Law) (2007)
  • University of Johannesburg (LLB) (2005)

Languages

  • Afrikaans
  • English
  • Portuguese