Tax Disputes

Tax Disputes Saving taxpayers millions in undue taxes penalties and interest through the tax dispute resolution process.

We resolve SARS matters faster and our strategy ensures a positive outcome, almost always before Tax Court. We provide individuals, corporates and high net worth taxpayers with technical tax assistance during a dispute with SARS. Our fine-comb approach includes compliance with tax legislation and related statutory requirements, pro-active and optimal tax planning, and rendering legal assistance for defensible matters prior to and in Tax Court.

Tax litigation is often viewed as the ultimate mechanism for resolving a dispute with SARS. Where the parties cannot agr...
09/09/2026

Tax litigation is often viewed as the ultimate mechanism for resolving a dispute with SARS. Where the parties cannot agree, the assumption is that the Tax Court will provide the answer.

In this matter, the dispute concerns a R6.65 million VAT input tax deduction claimed by the taxpayer but disallowed by SARS. Yet, after years of audit, objection, appeal and litigation, the Tax Court has still not determined whether that deduction should have been allowed.

For taxpayers considering litigation against SARS, this case provides a powerful reminder that winning a procedural battle can still leave both parties some considerable distance from resolving the actual tax dispute, whilst the taxpayer continues to foot their ever-growing legal bill.

As featured in Polity.

Read the full article: https://bit.ly/469Ok5o

Tax litigation remains an important part of South Africa's dispute resolution framework. However, recent developments su...
08/09/2026

Tax litigation remains an important part of South Africa's dispute resolution framework.

However, recent developments suggest it should not always be the starting point.

Prolonged procedural battles can delay resolution, increase costs and shift focus away from the real tax issue.

The most effective tax disputes are not necessarily those fought the longest, they are the ones resolved strategically.

Learn when litigation helps, and when it may do more harm than good. Read the full article: https://bit.ly/4x0tz88

When SARS makes a decision that could materially affect a taxpayer, should SARS also have to reveal the basis on which i...
04/09/2026

When SARS makes a decision that could materially affect a taxpayer, should SARS also have to reveal the basis on which it reached that decision?

A recent High Court judgment has reinforced that taxpayers must be able to understand and test the basis of decisions made against them, particularly when those decisions are brought under judicial review.

The judgment draws an important line between taxpayer confidentiality and SARS' obligation to remain accountable for how it exercises its extensive statutory powers.

As featured in Polity.

Read the full article to understand why, when properly challenged, SARS must show its hand: https://bit.ly/4zX9otu

One important question remains unanswered in SARS' updated Voluntary Disclosure Programme (VDP) Guide. While the Guide p...
03/09/2026

One important question remains unanswered in SARS' updated Voluntary Disclosure Programme (VDP) Guide.

While the Guide provides greater clarity on many aspects of the programme, it offers little guidance on how interest remission should be considered alongside a Voluntary Disclosure application.

For many taxpayers, accumulated interest can represent a significant portion of their overall tax liability, making it important to understand the latest guidance before taking action.

Read the full article to understand the latest SARS guidance on the Voluntary Disclosure Programme: https://bit.ly/4x1IAW7

A landmark Supreme Court of Appeal judgment has confirmed that taxpayers may be represented in the Tax Court by duly aut...
01/09/2026

A landmark Supreme Court of Appeal judgment has confirmed that taxpayers may be represented in the Tax Court by duly authorised non-legal practitioners.

While the judgment expands representation rights, it also reinforces an important reality.

Modern tax disputes have become increasingly procedural and require careful strategic management from the earliest stages.

Find out what this landmark judgment means for taxpayers and their choice of representation. Read the full article: https://bit.ly/4wSjQQR

Can SARS revisit historic tax years? Many taxpayers believe that once a tax year closed, it can no longer be revisited b...
27/08/2026

Can SARS revisit historic tax years?

Many taxpayers believe that once a tax year closed, it can no longer be revisited by SARS.

However, SARS' updated Voluntary Disclosure Programme (VDP) Guide confirms that where there has been fraud, misrepresentation or a material omission, older tax periods may still be subject to review.

As SARS continues to strengthen its data analytics and information-sharing capabilities, understanding your historic tax position has become increasingly important.

Concerned about historic tax non-compliance? Read the full article and contact our tax specialists to understand your options: https://bit.ly/45QfPRj

Our Tax Debt & Dispute Resolution Masterclass is underway with Jashwin Baijoo, Partner & Head of Strategic Engagement & ...
25/08/2026

Our Tax Debt & Dispute Resolution Masterclass is underway with Jashwin Baijoo, Partner & Head of Strategic Engagement & Compliance, and André Daniels, Head of Tax Controversy & Dispute Resolution.

The session is taking advisers beyond theory and into the practical realities of resolving tax debt, managing disputes and engaging effectively with SARS.

Missed this session? Keep an eye on our page for more upcoming events and webinars featuring practical insights from our specialists: https://bit.ly/4gRi6So

Success in a tax dispute is about more than securing a favourable court judgment. The best outcome is one that considers...
25/08/2026

Success in a tax dispute is about more than securing a favourable court judgment.

The best outcome is one that considers the broader commercial picture, including cost, time, business continuity and certainty.

Today's dispute strategies are increasingly focused on resolving matters in a way that delivers long-term value, rather than simply pursuing a legal victory.

Before pursuing litigation, understand the hidden costs that many taxpayers overlook. Read the full article: https://bit.ly/4fQJU98

5 days to go until our Tax Debt & Dispute Resolution Masterclass. Is your strategy ready for the next complex SARS matte...
20/08/2026

5 days to go until our Tax Debt & Dispute Resolution Masterclass. Is your strategy ready for the next complex SARS matter?

Join Jashwin Baijoo (Partner & Head of Strategic Engagement & Compliance) and André Daniels (Head of Tax Controversy & Dispute Resolution) on 25 August 2026 from 10:00 - 11:00 (SA Time) for our complimentary session focused on practical strategies for managing tax debt and disputes with SARS.

See how these challenges are addressed in practice, from resolving tax debt issues and handling objections and appeals to protecting client interests and engaging effectively with SARS throughout the process.

Take practical SARS strategies back to your clients. Reserve your complimentary spot: https://bit.ly/4cQlE4V

"The draft rules provide much-needed certainty regarding how the legislative regime will operate in practice." That is t...
18/08/2026

"The draft rules provide much-needed certainty regarding how the legislative regime will operate in practice."

That is the key takeaway from SARS' latest proposal introducing a procedural framework for Customs and Excise Voluntary Disclosure Relief.

While the legislative requirements remain unchanged, the proposed rules set out how applications will be administered and include practical measures that could encourage more businesses to voluntarily regularise historical customs and excise non-compliance.

Discover the key proposals and why they matter: https://bit.ly/4gBHhZ8

As featured in Daily Investor and Polity

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