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.

SARS has expanded its interpretation of the Voluntary Disclosure Programme (VDP), but one major issue remains unanswered...
03/06/2026

SARS has expanded its interpretation of the Voluntary Disclosure Programme (VDP), but one major issue remains unanswered: interest remission.

In his latest article, André Daniels, Head of Tax Controversy & Dispute Resolution at Tax Consulting SA, explores SARS’ updated VDP guide and what it means for taxpayers facing historic tax exposure.

“For many taxpayers, the uncertainty surrounding interest remission may materially impact whether disclosure remains commercially viable at all.”

Read the full article here: https://bit.ly/4a4InJe

As featured in Polity.

Tax litigation is often viewed as the ultimate solution when disputes with SARS escalate, especially where billions of r...
01/06/2026

Tax litigation is often viewed as the ultimate solution when disputes with SARS escalate, especially where billions of rands are at stake. But what if “winning” in court still comes at a significant cost?

In his latest article, André Daniels, Head of Tax Controversy & Dispute Resolution at Tax Consulting SA, explores the growing reality that litigation does not always deliver the commercial certainty taxpayers expect.

As Daniels explains: “Winning a case is one outcome. Achieving a result that is commercially sustainable, time-efficient, and aligned with the taxpayer’s broader objectives is another.”

Read the full article to understand why taxpayers should think twice before litigating: https://bit.ly/3PzELbn

As featured in Business Report, IOL and Polity.

28/05/2026

Many taxpayers only realise the consequences of non-disclosure to SARS once they have already been identified.

Penalties can reach up to 200% of the tax default, and in certain cases, criminal prosecution may follow.

The Voluntary Disclosure Programme (VDP) offers taxpayers a chance to come forward voluntarily, correct past non-compliance, and reduce exposure to severe penalties.

VDP applies to various taxes, including Income Tax, VAT, and employees’ tax such as PAYE, SDL, and UIF.

If you believe you may qualify for the VDP or need guidance on your tax position, contact our team to discuss your options confidentially: https://bit.ly/3PL9T7J

The Supreme Court of Appeal (SCA) has confirmed that taxpayers may be represented in the Tax Court by duly authorised no...
25/05/2026

The Supreme Court of Appeal (SCA) has confirmed that taxpayers may be represented in the Tax Court by duly authorised non-legal practitioners.

The judgment represents a significant limitation on SARS’ procedural litigation strategy and reinforces the growing complexity of modern tax disputes.

Tax disputes are not merely accounting exercises, they increasingly involve litigation strategy, procedural law, and constitutional interpretation.

Read André Daniels, Head of Tax Controversy & Dispute Resolution at Tax Consulting SA, full analysis here: https://bit.ly/4dHd5Jj

As featured in News24, BusinessTech, Daily Investor, IOL, Independent on Saturday, and Polity.

The proposed 2026 legislation empowers at least 14 government bodies to conduct lifestyle audits and share findings with...
21/05/2026

The proposed 2026 legislation empowers at least 14 government bodies to conduct lifestyle audits and share findings with SARS.

This means you may be flagged through multiple channels, not just by SARS directly.

Once identified, the consequences can escalate quickly, including additional tax assessments, penalties, and potential criminal prosecution.

The Voluntary Disclosure Programme (VDP) is voluntary and only available if you act before you are identified — so the real question is, are your affairs in order, or could this catch you off guard?

Contact our team to assess your position and act before it is too late: https://bit.ly/4uK5gJJ

Tax litigation remains an important part of South Africa’s dispute resolution framework, particularly where matters of p...
19/05/2026

Tax litigation remains an important part of South Africa’s dispute resolution framework, particularly where matters of principle must be determined.

However, many tax disputes are becoming increasingly focused on procedural manoeuvres, technical arguments, and litigation rules, rather than the underlying tax issue itself.

As a result, timelines are extended, costs increase, and meaningful resolution is often delayed. Recent judgments have reinforced the importance of correctly framing disputes from the outset, as the way an objection is approached can shape the trajectory of the entire case.

Read the full article to learn more: https://bit.ly/4dsrFG1

As featured in News24 and Polity.

Luxury travel, exotic vehicles, high-end assets… these are no longer just personal milestones. They can form part of a b...
14/05/2026

Luxury travel, exotic vehicles, high-end assets… these are no longer just personal milestones. They can form part of a broader picture when lifestyle audits are conducted.

Proposed 2026 changes expand the number of government bodies that can identify and report discrepancies to SARS.

If your lifestyle does not align with your declared income, the consequences can escalate quickly, unless you act first.

The Voluntary Disclosure Programme (VDP) allows you to regularise your affairs proactively, before any authority flags you.

Speak to a specialist today to assess your position and take control before questions are asked: https://bit.ly/3RCqV8r

When SARS raises a query or issues an assessment, the instinct is often to respond quickly. However, an early response t...
12/05/2026

When SARS raises a query or issues an assessment, the instinct is often to respond quickly.

However, an early response that is incomplete, unclear, or not fully aligned with the relevant tax legislation can complicate the matter further.

Each submission forms part of the record and may influence how the dispute progresses through objection, appeal, or Alternative Dispute Resolution (ADR).

Taking a structured and considered approach from the outset allows for a stronger and more consistent position throughout the process.

Before submitting your response, contact our tax disputes team to ensure your position is clearly defined and strategically aligned: https://bit.ly/3PVGTtD

What defines the case? In his latest article, André Daniels, Head of Tax Controversy & Dispute Resolution at Tax Consult...
11/05/2026

What defines the case?

In his latest article, André Daniels, Head of Tax Controversy & Dispute Resolution at Tax Consulting SA, explores how the Court clarified an important principle:

“The assessment must stand or fall on the factual and legal basis on which it was issued.”

The ruling highlights:
- The importance of a clearly defined case from the outset
- The role of the legal framework in guiding disputes
- The ability for parties to refine their arguments within the same dispute

Read more here: https://bit.ly/4eysgH2

This legislative shift is already underway in 2026, with developments progressing as we move through the second quarter....
08/05/2026

This legislative shift is already underway in 2026, with developments progressing as we move through the second quarter.

Under the proposed law, at least 14 government bodies will be empowered to conduct lifestyle audits and share information with SARS.

This means tax non-compliance may no longer be identified by SARS alone, but through intelligence gathered across multiple state entities.

As detection expands, the opportunity to proactively regularise non-compliance through the Voluntary Disclosure Programme (VDP) becomes increasingly time sensitive.

Read the full article: https://bit.ly/4d5iz0k

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