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Nicole Paulsen | Senior Associate | Tax | South Africa

Nicole Paulsen

Senior Associate

CMS RM Partners
85 Grayston Drive
5th Floor
Sandton, 2196
Johannesburg, Gauteng
South Africa
Languages English, Afrikaans

Nicole is a tax lawyer. 

She is an admitted Attorney and specialises in, inter alia, tax structuring solutions for corporates and high-net worth individuals.

Nicole assists her clients by identifying tax risks and inefficiencies and provides solutions, including but not limited to, domestic and cross-border structuring (inbound and outbound), employees’ tax and indirect tax. She also assists and defends clients in negotiating resolutions with South African Revenue Services (SARS) and regulatory authorities and provides advice in relation to the SARS Voluntary Disclosure Programme.

She is also experienced in providing advice on group restructures and share-buy-back transactions. 

Nicole provides advice to a wide range of clients including global wealth planning organisations, high-net worth individuals, listed and unlisted entities, financial institutions and mining companies. She has experience working in various industries including wealth planning, banking, online gaming, retail, logistics, real estate and mining. 

Nicole started her tax career at a large multinational law firm in 2011. In 2017, she joined a large family wealth planning organisation as part of a strategic career move to expand her knowledge and experience in tax and exchange control related matters pertaining to domestic and cross-border transactions. Nicole joined CMS South Africa, where she is currently an advisory specialist.

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Relevant experience

Regulatory, tax & exchange control

  • High-net worth individuals – in relation to financial emigration and the cessation of tax residency. Advice included the tax and exchange control implications of ceasing tax residency and / or financially emigrating and lodging and facilitating emigration applications on behalf of clients.
  • High-net worth individuals – in relation to offshore structuring. Advice included reviewing the current domestic and offshore personal and corporate structures and providing alternative structuring methodologies. 
  • Performanta (Pty) Ltd – in relation to its BEE scheme and related tax consequences.
  • Osiris Trading – in relation to assisting with the online betting and games group with its Africa expansion.  The services provided included understanding the regulatory framework of each subsidiary jurisdiction, particularly the tax riels applicable to the gaming industry and optimising problems areas including where no appropriate regulation exists.
  • A Global Property Group – in connection to the restructure of the group and proposed a structuring methodology for the acquisition of non-resident companies in Portugal and the United Arab Emirates. The structure involved creation of a trust to hold the offshore assets.
  • A Global Hotel Group – in relation to the offshore structuring for the group in light of the anticipated expansion into the African market. 
  • A Global Group – in relation to advice to the group on Exchange Control regulations and compliance regarding the export of intellectual property. 
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  • 2017 – Postgraduate Higher Diploma in International Tax from the University of Johannesburg, South Africa. 
  • 2013 – Postgraduate Higher Diploma in Tax Law from the University of Johannesburg, South Africa.
  • 2010 – LL.B., University of Johannesburg, South Africa.
  • 2008 - Bachelor of Commerce (Law) from the University of Johannesburg, South Africa.
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  • Member of the Law Society for the Northern Provinces.
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Lectures list

  • Annual Tax Indaba | Exiting South Africa: Pay-Before-You-Go – Migration from South Africa is not without cost. The tax and exchange control costs of migration (Mini-Panel Discussion) | 14 September 2017
  • Annual Tax Indaba | Shaking the already barren money tree: SARS collections (Panel Discussion) | September 2018
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7 October 2019
CMS ex­pands in Africa
South Afric­an and Kenyan law firms ad­ded to CMS’s glob­al...
December 2019
Eth­ics: the fu­ture of tax plan­ning
Tax Thought Lead­er­ship Bro­chure
March 2020
CMS Tax Glob­al Bro­chure