Training

Explore the key changes in SARS’ VDP Guide Issue 2, including eligibility, audit timing, voluntariness, penalties, cross-tax disclosure risks, rejection decisions and the finality of VDP agreements.

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

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.

This discussion examines the critical distinction between objecting to a SARS penalty assessment and requesting remittance under the South African Tax Administration Act.

It unpacks the interaction between sections 104, 215, 220, and 224, highlighting why taxpayers may first need to seek remittance before pursuing objection and appeal remedies and explores the procedural and evidentiary consequences of each route, particularly the shifting onus of proof in understatement penalty disputes and administrative penalties before SARS and the Tax Court.

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.

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.

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.

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.

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.

BASF South Africa (Pty) Ltd v CSARS confirms that SARS may not amend a Rule 31 statement to introduce a new legal or factual case, while a taxpayer may raise fresh Rule 32 appeal grounds where they relate to the same disputed assessment amount already objected to.