Ms. Nicole Paulsen will address the FISA Conference, sponsored by Hollard Court Bonds, on 9 September 2026 on the topic: “Exchange control and the proposed new regulations.” Mr. Andrew Wellsted will then discuss the recent Constitutional Court judgment of Absa Bank Ltd and Another v Commissioner for the South African Revenue Service, in which the general anti-avoidance rule (GAAR) was considered.
To register for the 16 th Annual FISA Conference – click here
The fiscal landscape in South Africa is changing rapidly for numerous reasons, including the instability of the international arena. Added to this, the General anti avoidance rule (GAAR) has recently been considered by the Constitutional Court in a matter between SARS and ABSA. The interpretation of the GAAR by the apex Court is diametrically opposed to what most technical commentators thought would be the position, creating real planning issues for commercial transactions. In addition, the draft Exchange Control regulations released by the National Treasury also contain numerous surprising elements which broaden the scope of the Financial Surveillance Department’s purview dramatically. Again, understanding these changes is critical to future planning.
Nicole Paulsen
Director, Tax | OWP Partners
Nicole Paulsen is a Founding Partner and Director in OWP Partners’ Tax practice. She is an admitted attorney and South African tax practitioner with extensive experience advising high-net-worth individuals, families, fiduciary professionals and corporate clients on complex South African and international tax matters.
Nicole specialises in wealth structuring, cross-border investments, exchange control and succession planning. She advises on the establishment and ongoing management of local and offshore structures, assists clients with the tax implications of trusts and estates, and provides strategic guidance on intergenerational wealth transfers and international mobility.
Her practice also includes advising on inbound and outbound investment structures, exchange control compliance, SARS disputes, voluntary disclosure applications and engagements with regulatory authorities. In addition, Nicole regularly advises on corporate restructures, mergers and acquisitions and other transactions requiring specialist tax input. Nicole is a recognised adviser on tax and exchange control matters affecting South African investors, fiduciary practitioners and internationally mobile families, and is a regular speaker on developments impacting the fiduciary and private wealth sectors.
This reads more senior, aligns with her Founding Partner status and speaks directly to the FISA audience’s interests in trusts, estates, wealth preservation, succession and exchange control.
Andrew Wellsted
Director, Tax | OWP Partners
Andrew Wellsted is a Founding Partner and Director of OWP Partners and heads the firm’s Tax practice.
Andrew is a highly regarded South African tax practitioner with extensive experience advising financial institutions, investment managers, multinational groups and high-net- worth individuals on complex domestic and international tax matters. His practice focuses on international tax structuring, cross-border investments, exchange control and the design and implementation of efficient ownership and investment structures.
He regularly advises private clients, family offices and fiduciary professionals on the tax and regulatory implications of offshore investments, international wealth structures, succession planning and the movement of assets across jurisdictions. He is particularly experienced in developing and implementing structures that balance commercial objectives, tax efficiency and regulatory compliance.
Andrew also has significant experience in tax disputes, voluntary disclosure applications and engagements with SARS and other regulatory authorities. He is known for his practical approach to solving complex tax and regulatory issues and for his ability to navigate the intersection of tax, exchange control and commercial considerations.