Opening Blows in Transfer Pricing Case Where SARS Fights for Additional R1 Billion of Taxable Income

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.

Voluntarily Disclose

Voluntarily Disclose to SARS or Face Severe Penalties, Even Imprisonment | A More Aggressive SARS: Project AmaBillions and a R7.5 Billion War Chest

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.

Import VAT Refund

9,000 Imported Gold Coins: Tax Court Ruling Leaves Taxpayer R26 million in VAT Out of Pocket

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.

SARS IT3 Submissions

SARS Sharpens Focus on Trusts and NPOs: Why IT3(d) and IT3(t) Submissions Cannot Be Delayed

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).

Do South African Expats Return Home for the Braais?

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.