Key Changes in SARS’
VDP Guide Issue 2

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.

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.

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.

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.

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.