Associate

Naledi Mdingi

Languages

English
Xhosa
Zulu

Social media

Naledi an Associate in the Tax and Exchange Control department at CMS South Africa.

She obtained her LLB degree from the University of Fort Hare in 2018 and subsequently obtained her LLM degree in commercial law from the University of Johannesburg in 2019.

Prior to joining CMS, Naledi was employed as an intern in the commercial legal department at MTN Group, where she assisted internal counsel in providing legal support in 23 countries in Africa and the Middle East and where she was exposed to TMT services and Digital & Fintech Services.

Naledi also has experience in Tax, Exchange Control, Dispute Resolution, Corporate Investigations & Forensics and Corporate M&A, Customs, Funds and Mining.

Relevant experience

Regulator - on various appeals relating to multi-peril contingency risk insurance agreements in which various taxpayers entered into with various insurance companies and claimed deductions in terms of section 11(a) of the Income Tax Act in respect of these contingency policies, on the basis that the payments constituted deductible expenditure in the form of insurance premiums.
Regulator - in a dispute dealing with section 11(2)(h) of the Eighth Schedule of the Income Tax Act read with the definition of ‘securities lending arrangement’ in section 1(1) of the Income Tax Act, and sections 92, 99 and 102 of the Tax Administration Act.
Regulator - in a dispute dealing with whether SARS’ decision to audit was reviewable in terms of PAJA.
A large financial institution - in relation to an income tax and VAT dispute against the Regulator.
A large cosmetics company - on a VDN application in respect of the importation of its cosmetics products into South Africa.
A large multinational financial institution – on submitting exchange control applications to the Regulator in respect of numerous transactions.
A large industrial manufacturing and distribution of construction material Group - on the development and implementation of an Employee Stock Ownership Plan.
A large UK software solutions company - on the development and implementation of three employee share schemes where some of the employees are based in South Africa.

Publications

Memberships & Roles

Admitted Attorney, High Court of South Africa
Member of the Legal Practice Council, South Africa

Awards & Rankings

Legal 500, South Africa, Tax | Tier 3, 2025

Education

2019 – LL.M, University of Johannesburg, South Africa
2018 – LL.B, University of Fort Hare, Eastern Cape, South Africa

Practice Areas

Tax

Insights

Global Reach