Tax law in motion.
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Analysis, commentary and practical guidance on SARS disputes, tax administration, voluntary disclosure and the decisions shaping South African tax.
Lueven Metals – the limits of interpretation in tax law
Why text, context and purpose must work together – without stretching statutory wording beyond what it can reasonably bear.
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Commentary shaped by real disputes, legislation, judgments and SARS practice.
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Short, practical and candid analysis of the latest tax issues.
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Meiring Citrus: Correct Result, Questionable Route?
11/09/2026The Meiring Citrus High Court judgment examines whether structured self-insurance arrangements qualify as deductible insurance premiums under section 11(a) of the Income Tax Act. The Court held that a Santam -
Company AF v CSARS – GAAR, Paragraph 43A and the Future of Dividend-Stripping Litigation
27/07/2026This training session examines the Company AF judgment and its impact on the General Anti-Avoidance Rule (GAAR), paragraph 43A, the choice principle, dividend-stripping arrangements, SARS’s litigation powers, and penalty disputes. -
Lueven Metals – The limits of interpretation in tax law
30/06/2026This training session unpacks the Constitutional Court’s decision in Lueven Metals and its significance for tax interpretation. It explains why text, context and purpose must be read together, but cannot -
VAT Consequences of Unlawful Transactions
30/06/2026Explore the VAT consequences of unlawful and subsequently invalidated transactions through a detailed analysis of the Ndyamara / Swifambo judgment. This training examines the interaction between VAT liability, illegality, section -
Key Changes in SARS’ VDP Guide Issue 2
11/06/2026Explore 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. -
TAXPAYER EPP VS CSARS
11/06/2026In 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 -
Binding Private Ruling 428
11/06/2026Binding 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 -
Chapter 15 penalties and holding SARS Accountable
25/05/2026This 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, -
Absa and Another v CSARS [2026] ZACC 15
25/05/2026A 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. -
It’s Never Just Timing: The Deduction Risk Hiding in the Wrong Tax Year
21/05/2026A Tax Court judgment on a wrong-year deduction highlights the risks of timing errors, section 11(a), VAT section 23C, reduced assessments and whether earlier years can still be corrected. -
Taxpayer Bank Limited v SARS (VAT 32666)
05/05/2026This 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 -
X and Another v CSARS (A117/2025)
29/04/2026SARS 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
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