TRaining

TAXPAYER EPP VS CSARS

Overview

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

Notes

Download publication

Legal-DRJ-TC-2026-05-SARSTC-IT-24852-IT-ZATC-JHB-14-April-2026 (90 downloads)

Download notes

Taxpayer EPP v Commissioner for SARS Notes (101 downloads)