Key Changes in SARS’
VDP Guide Issue 2

SARS objection to estimated assessments dismissed: Western Cape High Court confirms taxpayers must submit substantiating documents under Rule 7(2)(b)(iii), even where SARS bears the onus of proving an estimated assessment’s reasonableness.

Debts are often written off or restructured in some way. These typically tend to have tax consequences. This session discusses what those tax consequences are.

SARS’ interpretation note 142 purports to be a note explaining what constitutes “similar finance charges” for the purposes of section 24J when really, it appears rather to be aimed mainly at contradicting a tax court judgment handed down a year earlier in favour of a taxpayer. In essence, the question is whether raising fees are deductible. The court says it is, SARS says its not. Who is right?

A comprehensive analysis of Absa and Another v CSARS, examining SARS’s application of the General Anti-Avoidance Rules (GAAR) to complex preference share funding structures.

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.

Binding Private Ruling 428 examines the income tax consequences of a Delayed Contribution Equity Investment Structure (DCEIS), confirming that phased share subscription proceeds constitute contributed tax capital rather than gross income.

The ruling also clarifies the interaction between sections 11D and 8(4)(a), confirming that qualifying R&D expenditure remains deductible without triggering recoupment consequences under the Income Tax Act.