Eliya Nkerebuka

Full Profile

Eliya is a versatile tax lawyer and consultant with experience in serving local and foreign multinational companies in various sectors including, telecom, energy, mining, hospitality, oil and gas, banking and education. 

Prior to joining Clyde, he worked for EY Tanzania and was seconded to the tax department in EY Kenya (Nairobi) office. Eliya has successfully been able to cultivate strong tax teams by building, developing, mentoring and leading high performance teams. 

He is able to significantly impact financial performance through the development and implementation of innovative strategies that minimize tax costs. Eliya has also successfully led external tax audits, tax cases and settlement negotiations with the tax authorities

He is a duly registered tax consultant and advocate and a member to both the Tanganyika Law Society and the East African Law Society.

Experience

• Leading the tax advisory team in reviewing framework agreements and financial models of mining companies during negotiations with the Government of Tanzania.    
• Defending clients against application of Tanzania taxing rights on service fees paid to South Africa tax residents contrary to the double tax treaty between Tanzania and South Africa. 
• Leading the tax advisory and tax controversy team at one of the Big Four accounting firms.
• Leading the tax advisory team in multiple mergers, acquisitions, corporate reorganisations and joint ventures.
• Advising on tax efficient strategies for inbound and outbound investments with respect to entry and exit of investors.
• Advising clients across different sectors on direct and indirect tax consequences of their business transactions and recommending tax mitigating ways. 
• Advising foreign multinationals on permanent establishment risks in Tanzania.
• Assisting businesses to object against tax assessments issued by the tax authorities.
• Successfully defending clients against imposition of withholding tax on accrual basis which has significant cash flow impact on businesses.
• Assisting businesses to object against tax assessments issued by the tax authorities.