Choosing Your “A-Team” in Tax Debt Write-Off Negotiations – Protection of Legal Privilege

 Stemming from SARS’ recent Revenue Result Announcement, and the pre-cursors of new compliance and collection initiatives over the last 5 years, Deferrals of Payment and Compromises of Tax Debt are all the market hype! Just the thought of being able to legally reduce your tax debts due to SARS, although sounding like a pipedream, […]

Tax Court Bullying Judgment Set-Aside and “court” status brought into question – Appeal Reignites Debate Over Lay Representation in the Tax Court

A recent tax dispute ruling has reignited the age-old debate over the right of appearance by a lay person in the Tax Court and whether the Tax Court falls within the ambit of a “court of law.” The High Court judgment in Poulter v CSARS (A88/2023) [2024] ZAWCHC 97 (2 April 2024) involved a taxpayer […]

“SARS + AI” vs “Your South African Tax”

The SARS Announcement on 02 April 2024, may look, for the untrained eye, like standard narrative. As a tax attorney in day-to-day practice, there are daily examples of very expensive tax mistakes. Tax practitioners and South African taxpayers are well advised to switch to a moment of seriousness; and take note of the following with […]

SARS Follows the Money – Targeting Big-Ticket Taxpayers and Their “Trusted Advisors”

SARS’ “Compliance Revenue Programme” make headlines off the back of the Revenue Results Announcement on 02 April 2024, raking in a whopping R293,7 billion! Even though the Announcement provided statistics upon statistics, the underlying message from Commissioner Kieswetter was clear – even with only 12 500 SARS employees, SARS will ensure to be “a catalyst to […]

SARS Commissioner vs Tax Practitioners: “Do your due diligence”.

During the April 2024 SARS Revenue Results Announcement Media Conference, the SARS Commissioner brought to light concerning observations regarding non-compliance and delinquent behaviour by tax practitioners. By drawing a direct correlation between non-compliant tax practitioners and their “clients [who] are equally delinquent,” his remarks underscored the critical importance for taxpayers to carefully assess the quality […]

SARS Wheels Against Eskom Corruption Turning Slowly, but Days are Numbered

Like all strategic movers, SARS has been biding its time in addressing corruption amidst South African SOEs, taking a few direct, or indirect shots here and there, and like a Grand Master, the Commissioner has made clear his end goal – the complete eradication of non-compliance.

Wealth Preservation and Residence by Investment for South Africans

For decades, the affluent South African has searched for ways to preserve their wealth, in such a way as to ensure their descendants do not have to start from the bottom as they did. This has in most instances, lead South Africans to explore offshore investment and insurance options, including the creation of offshore Trusts […]

Tax Residence Certificates for SA Expats: SARS’ way or the highway

Many South African (SA) expats already recognize that the Notice of Non-Resident Tax Status Letter (the letter) is their golden ticket to confirming their cessation of tax residency. A Tax Residence Certificate (TRC) from one’s new country of residence provides substantial evidence that one is now resident for tax purposes in their new country, aiding […]

Safeguarding your South African Company: Potential Impact of CIPC Information Breach

Reparative measures may have been taken to remedy the Companies and Intellectual Property Commission hack which reportedly took place on 29 February 2024 however this information breach may have long-lasting and detrimental effects!

Ceasefire of Section 164 Suspensions of Payment, in SARS’ War on Non-Compliance

Dispelling accusations of any revenue collector can feel like the fight of your life, especially where you are factually not on the wrong side of the law! Amongst these collectors, SARS stands firm as one of the most strategic movers, turning the fight into an all-out war, the War on Non-Compliance!