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Corpus has a team of lawyers that advises its clients on all aspects of tax. Our strength in transactions and structuring, tax disputes and investigations, trade and customs, employee incentives and transfer pricing are at the core of our services. Our team ensures that clients are kept up to date with the changes in tax laws. Some of the clients that have been advised on tax matters include:


Enel Green Power RSA (Proprietary) Limited (“Enel”): Advisor to Enel with tax advice for its 34-megawatt solar PV project in Zambia (the ‘Ngonye Project’). This project is ground-breaking and important because it one of two of the first utility scale solar projects in Zambia and in 2016 at 7.84c/kWh it yielded (and still is) one of the lowest electricity tariffs on the continent, through the World Banks scaling solar program


BayWa r.e. Solar Projects GmbH (“BayWa”): Advisor to BayWa a global renewable energy developer, service supplier, wholesaler and energy solutions provider, in relation to the tax implications of constructing a utility scale solar power in Zambia pursuant to a USD 1.3 million construction contract awarded to Baywa by Copperbelt Energy Corporation (CEC)


Jumo Zambia Limited (“Jumo Zambia”): Advisor to Jumo Zambia on tax credit application for the refund of overpaid interest withholding tax and on the mitigation of the Reverse Charge VAT (RCVAT) in relation to transaction between Jumo Zambia and Jicama


Razel–Bec: Advisor to Razel–Bec, a French engineering firm awarded a contract by Zambia and Zimbabwe to perform dam safety repairs at the 1830-MW Kariba hydroelectric plant, on the various tax implications of setting up a subsidiary company in Zambia to carry improvement works and related activities necessitating engagement of foreign nationals


Chambishi Metals Plc (“Chambishi Metals”): Advisor to Chambishi Metals on tax liabilities from Zambia Revenue Authority associated to the dissolution of Swanex Zambia Limited


MTN Zambia: Advisor to MTN Zambia in relation to a tax audit by the Zambia Revenue Authority (ZRA) and the dispute arising from Customs and Excise duty assessment following the audit


BP Southern Africa (“BPSA”): Advisor to BPSA in a dispute with Zambia Revenue Authority (ZRA) with respect to the classification of a mineral solvent leading to an assessment by ZRA of alleged taxes, interest and penalties to the value of USD18, 504, 441


September 25, 2021

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