VAT Ruling 014

Binding Private Ruling 424 examines whether interest on a loan used to redeem preference shares and settle related dividends is deductible under section 24J of the Income Tax Act.

This Tax Court VAT Section 21 Judgment examines the VAT treatment of financial services, focusing on whether certain banking activities qualify as exempt supplies.

The case highlights the interpretation of “financial services” under VAT legislation and clarifies the boundaries between taxable and exempt transactions, offering key insights into compliance, input tax claims, and structuring within the banking sector.

Supreme Court of Appeal dismisses SARS’s appeal in CSARS v Erasmus, holding that SARS could not use a rule 31 statement to revise the factual basis and remedy of a GAAR assessment after issuing the assessment.

“A significant High Court ruling on SARS discretion under the ‘pay now, argue later’ rule, highlighting the importance of rational decision-making, adequate security, and procedural fairness in tax disputes.”

In SARS v Taxpayer 3C (VAT 12167, 2026), the Tax Court held that SARS must apply for condonation when filing a Rule 31 statement late, confirming that a taxpayer’s clear communication can constitute valid notice to proceed with an appeal and trigger SARS’s obligations under the Tax Court Rules.

This session explores an SCA judgment regarding the imposition of understatement penalties for submission of nil returns as well as the strength of the “professional tax advice defence”.