Kyle Fyfe is a Director in the Tax & Exchange Control practice area. He specialises in tax dispute resolution, international and domestic corporate taxation, trusts and estate planning, value-added tax, employees’ tax and South African exchange controls.
Years of Experience: 8 years
Tax
Tax dispute resolution;
International and domestic corporate tax advisory;
Taxation of financial instruments and insurance products;
Value-added tax;
Employees' tax; and
South African exchange control.
Representing SARS in approximately tax appeals by a group of companies and related individuals, which were settled in favourable terms to SARS
Representing taxpayers in tax appeals relating to depreciation allowances, the general anti avoidance rules, prospecting allowances and value added tax
Advising listed and unlisted corporates on the establishment and taxation of employee incentive schemes
Advising listed and unlisted corporates, trusts and individuals on the use of corporate rollover relief rules
Advised high net worth individuals on the exchange control and tax aspects of emigration
Advice to trustees and high-net worth individuals regarding the application of South African tax laws to offshore trust structures
Admitted as an Attorney, South Africa, 2015
LLB, University of the Witwatersrand, 2012 (with distinction)
LLM, University of Pretoria (Tax Law), 2017 (with distinction)
Admitted as a Solicitor, England and Wales, 2023
Recognised by ITR as Notable Practitioner | Tax Controversy | 2025
Kyle received numerous academic awards for his academic achievements in his studies, including the Dean's List award and the Jane Ewing Memorial Prize for Public International Law.
Johannesburg 
+27 11 535 8241 
