The South African Revenue Service (“SARS”) is no longer the passive revenue service many South Africans remember. With the injection of R3.5 billion from the national budget and the ominous launch of “Project AmaBillions,” SARS has entered its most aggressive phase of enforcement in years and is quickly turning into one of the most sophisticated, assertive, and unrelenting revenue authorities in the world.
According to recent media reports, SARS has launched a new initiative — Project AmaBillions — as part of its broader strategy to boost revenue collection by an additional R70 billion over the next three years.
On 15 April 2025 the Tax Court heard the opening skirmishes in what may develop into one of South Africa’s largest and most complex Transfer Pricing cases. At stake is an adjustment of R1 billion on the taxable income of a JSE listed company, translating to roughly R280 million in additional taxes for just two years of assessment.
The South African Revenue Service (SARS) is preparing to escalate its enforcement drive. With R7.5 billion in additional funding over the medium term and the implementation of a focused initiative known as Project AmaBillions, SARS now has both the mandate and the means to pursue non-compliant taxpayers with renewed vigour.
SARS Commissioner Edward Kieswetter has spelled it out again after the May 2025 Budget Speech: SARS is committed to collecting significantly more tax this year. He warned that the South African Revenue Service (SARS) will use all legal instruments to address non-compliance.
In its effort to meet the ambitious 2025/26 revenue estimate of R1.986 trillion, the South African Revenue Service (SARS) has made it clear that timely, transparent and accurate tax submissions are the new normal. Central to this approach is expanded use of third-party data, not sparing Trusts and Non-Profit Organisations (NPOs).
The fact that several countries abroad do not let you have a braai whenever and wherever you want, is not on its own the reason why South African expats return home after many years abroad. But when added to factors like cultural differences, the lack of traditional support structures, and the high cost of living overseas, it might just be the final straw.
If you’re still waiting on a VAT refund, now is the time to take legal action. Taxpayers and tax practitioners alike are reporting a surge in delayed refunds, with SARS citing pending verifications or audits, but only after a manual status check is performed. This is not a procedural glitch – this is a
systemic failure with serious financial implications.
The South African Revenue Service (SARS) is moving fast to tighten the tax net. This is not reform; it is an offensive – and entirely consistent with Commissioner Edward Kieswetter’s strategic mantra of making non-compliance hard and costly.
A recent Tax Court ruling in favour of the South African Revenue Service (“SARS”), which treated large loan account balances as undeclared income, serves as a warning to directors and shareholders to properly manage these accounts, maintain accurate records, and be prepared to explain the origin of funds when SARS flags loans as unexplained.