Binding Private Ruling 428

A practical training session on how section 210 now applies to trusts, what Notice 7314 actually does, why 4 May 2026 is not a universal cliff-edge, and how trustees should regularise carefully without panic-filing.

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.

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?

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.

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”.

This judgment highlights the binding nature of tax settlement agreements, affirming that SARS must honour lawfully concluded agreements as final and enforceable. It reinforces certainty, fairness, and trust in tax dispute resolution by preventing SARS from deviating from agreed terms after compliance by the taxpayer.