Ntayiya v South African Revenue Service

Supreme Court of Appeal dismisses reconsideration in Lutzkie v SARS, holding that no exceptional circumstances justified revisiting refusal of leave to appeal on disputed taxable income and penalties.

A practical training session on understatement penalties before and after 1 April 2026, covering the impact of the Coronation and Thistle cases, the BFIE amendment, and what the new rules mean for taxpayers and advisers.

SARS Interpretation Note 64 (Issue 5) clarifies the income tax exemptions under section 10(1)(e) of the South African Income Tax Act for bodies corporate, share block companies, and qualifying associations of persons, including rules on exempt levy income, basic exemptions on other receipts, and application requirements for associations.

In this practical training session, we unpack Tax Court judgment IT 24852 (Taxpayer EPP v SARS), where a taxpayer sought to deduct R38.8 million after customs and excise refund claims became time-barred. Explore the critical distinction between expenditure and loss under section 11(a), the timing of deductions, the impact of prescribed refund claims, understatement penalties, interest, and potential post-judgment remedies through reduced assessments and prescription exceptions under the Tax Administration Act

This judgment underscores the procedural limits in tax litigation, clarifying that taxpayers may not introduce entirely new grounds of appeal that effectively constitute new objections to previously undisputed aspects of an assessment. It reinforces the principles of finality, fairness, and procedural integrity in the objection and appeal process under the Tax Administration Act.

VAT Ruling VR 014 (9 January 2026) approves the page-space and varied turnover-based apportionment methods under sections 17(1) and 41B of the VAT Act.