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Tax Disputes

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Tax Disputes

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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.

03/11/2026

Lodging an objection or appeal does not automatically suspend your obligation to pay the disputed tax or SARS’ right to collect it.

Where a taxpayer is disputing an assessment, the question of payment and collection may need to be dealt with separately.

Depending on the circumstances, this can include considering a request for suspension of payment while the dispute is being resolved.

If you are facing a SARS dispute together with collection action, getting the strategy right from the outset matters: https://bit.ly/4s5Dmru

29/10/2026

Offshore does not necessarily mean outside SARS' reach.

Historic income connected to offshore assets or investments may create a South African tax exposure where the required amounts were not correctly declared.

Where a tax default exists, the Voluntary Disclosure Programme (VDP) may provide a route to regularise your affairs.

Have historic offshore income or assets that you are uncertain about? Get clarity on your tax position before taking the next step: https://bit.ly/47kFL8u

28/10/2026

A recent Johannesburg High Court judgment has highlighted the limits of SARS' discretion when refusing to reconsider tax assessments, particularly where tax returns have allegedly been submitted fraudulently by persons acting without the taxpayer's authority.

In TEG Asset & Risk Management CC v Commissioner for SARS, the High Court reviewed and set aside two decisions by SARS refusing to issue reduced assessments.

The judgment provides an important reminder that SARS must carefully consider the circumstances surrounding disputed tax returns, rather than relying exclusively on the formal appointment of a juristic taxpayer's public officer.

For taxpayers facing substantial historical tax liabilities arising from the conduct of accountants or tax practitioners, the decision offers valuable insight into the remedies available under the Tax Administration Act.

As featured in Polity and IOL News.

Read the full article: https://bit.ly/4kcu1fK

27/10/2026

A tax dispute does not happen on your timeline.

From responding to SARS to progressing through the dispute process, procedural requirements and deadlines matter.

A missed deadline may require an application for an extension, which is subject to legal requirements and limits.

Our Tax Disputes team assists with both the strategy and process behind SARS disputes: https://bit.ly/4jWrXs6

26/10/2026

A recent Tax Court judgment has upheld SARS's decision to disallow approximately R65.6 million in tax deductions, highlighting the risks for businesses claiming expenses incurred on behalf of associated companies, even where binding commercial agreements exist.

“A commercially sound agreement is not necessarily a tax-efficient agreement.”

Richan Schwellnus, Team Lead: Tax Controversy & International Tax at Tax Consulting South Africa, unpacks the judgment and its implications for businesses.

Read the full article: https://bit.ly/4i6YMBn

As featured in Polity and Daily Investor

22/10/2026

Finding an error in an old tax return does not necessarily mean the problem has disappeared because the tax year has passed.

SARS' updated Voluntary Disclosure Programme (VDP) guidance confirms that older tax periods may still be reviewed in circumstances involving fraud, misrepresentation or a material omission.

Before correcting historic information, it is important to understand the nature of the default and whether the VDP may be relevant.

Found something in an old return that concerns you? Have your historic tax position assessed before taking action: https://bit.ly/4zwjlgl

21/10/2026

SARS is intensifying its crackdown on VAT refund fraud, with 14 accused appearing in court over an alleged R3.99 million fraud scheme.

“Deliberate manipulation of tax declarations can expose businesses, directors and other implicated parties to significant financial and criminal consequences.”

Richan Schwellnus, Team Lead: Tax Controversy & International Tax at Tax Consulting South Africa, examines the consequences of VAT fraud, SARS's strengthened investigative capabilities and the distinction between legitimate tax disputes and criminal misconduct.

Read the full article: https://bit.ly/4zHX2Ex

As featured in Polity.

Tax Legal

20/10/2026

Receiving an assessment from SARS that you disagree with does not mean your only option is to accept it.

Start by identifying what you believe is incorrect, understanding the basis of the assessment and checking the applicable deadlines.

Facing an assessment, you believe is incorrect? Speak to our Tax Disputes team about the appropriate way forward: https://bit.ly/4zwtbPp

15/10/2026

Rental income received over previous tax years but not correctly declared may leave you with a historic tax default.

SARS' Voluntary Disclosure Programme (VDP) provides taxpayers with an opportunity to regularise historic tax defaults before SARS takes enforcement action.

The important question is not simply whether income was left off a return, but whether your circumstances meet the requirements for a valid voluntary disclosure.

Unsure whether your historic rental income creates a VDP concern? Speak to our team to assess your position: https://bit.ly/4yrrpyf

14/10/2026

Filing an objection to SARS is only one part of a tax dispute. What happens afterwards can be just as important.

The recent Africa Cash and Carry judgment highlights how decisions made during a tax dispute, from suspension of payment arrangements to asset transfers, can have consequences years later.

As Richan Schwellnus, Team Lead: Tax Controversy & International Tax at Tax Consulting South Africa, highlights: “Tax dispute resolution cannot be reduced to drafting a technically sound objection.”

Read his latest article as he unpacks the judgment and the lessons taxpayers cannot afford to overlook: https://bit.ly/4yO1BgD

As featured in Polity.

Address

17 Eaton Avenue
Four Ways
2191

Opening Hours

Monday	08:00 - 17:00
Tuesday	08:00 - 17:00
Wednesday	08:00 - 17:00
Thursday	08:00 - 17:00
Friday	08:00 - 17:00

Telephone

+27114670810

Website

https://www.taxconsulting.co.za/adr-tax-dispute-resolution/

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