The South African Revenue Services’ (SARS) provisional sequestration of Mr Roy Muleya, sole director of a company with a tax liability of about R155 million, underscores the serious consequences of tax non-compliance, as confirmed by the North Gauteng High Court on 29 October 2025.
Jashwin Baijoo
Associate Director and Head of Strategic Engagement & Compliance
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This most recent notch in SARS’ belt clearly evidences the revenue authority’s far-reaching powers, and zero-tolerance on non-compliance.
To commemorate this win, SARS Commissioner Edward Kieswetter commented:
“Where taxpayers opt to wilfully disregard their obligations by acting outside the remit of the law, SARS will make it hard and costly.
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SARS will continue to act lawfully and decisively against those who deliberately seek to evade or neglect their tax responsibilities. The message we want to communicate is that no matter how long it takes, SARS will not abdicate its responsibility to enforce the law.”
SARS’ Compliance Crusade – Key Collection Driver
In Mr Muleya’s case, the legal action taken by SARS, places an individual’s estate under external administration due to insolvency or unpaid debts, particularly related to tax liabilities. Such measures indicate a rigorous approach to financial management, aiming to protect state revenue while targeting defaulters without hesitation.
The objective of making non-compliance hard and costly, has shown a clear positive impact on SARS’ tax debt collections.
Case in point is SARS’ 2024/25 Annual Report, published on 30 October 2025, which revealed a whopping net revenue collection of R1,855.3 billion, from which the largest contributor remains personal income tax, bringing in R733.2 billion. This taxpayer segment alone, showed a 12.6% collection increase from the 2023/24 period.
Excerpt from SARS’ 2024/25 Annual Report
SARS’ Enhanced Enforcement Against Tax Avoidance
The tax authority is strengthening its regulatory framework to combat tax evasion more effectively. This includes new regulations on Crypto-Asset Reporting and revisions to the Common Reporting Standards (CRS).
The seizure of assets from individuals like Mr Muleya is a clear message that SARS is prepared to employ severe measures against tax defaulters.
SARS’ strategy to instil a sense of urgency and responsibility among taxpayers hinges on making non-compliance both hard and costly. By detecting and addressing non-compliance rigorously, SARS aims to deter tax evasion and ensure that all taxpayers fulfil their obligations.
This approach emphasizes that no taxpayer, regardless of their economic standing, is beyond the reach of SARS’ compliance efforts. Recent trends in this regard have also shown SARS considering not just current compliance but also delving into historic risks of non-compliance, and in some instances, even requesting taxpayers to look into their crystal balls and provide SARS of income and expenditure estimates for future tax periods.
Enhancing Voluntary Compliance Through Technology and Trust
With SARS’ enhanced detection capabilities and a sharp focus on both past and future non-compliance, correct tax and legal guidance have never been more critical. The most prudent approach to be taken, is to heed SARS’ warning that non-compliance will be both hard and costly for taxpayers.
In order to protect yourself from financial ruin, and even possible jail-time, it remains the best strategy that you always ensure compliance.
Where you find yourself on the wrong side of SARS, there is a first mover advantage in seeking the appropriate tax advisory, ensuring the necessary steps are taken to protect both yourself and your unblemished record, from paying the price for what could be the smallest of mistakes. However, where things do go wrong, SARS must be engaged legally, and we generally find them utmost agreeable where a correct tax strategy is followed.
As a rule of thumb, any and all correspondence received from SARS should be legally addressed, as often legal professional privilege is a must in instances of non-compliance. This will not only serve in safeguarding against SARS implementing collection measures or potentially criminal charges, but also being specialists in their own right, taxpayers and practitioners will be correctly advised on the most appropriate solution to ensure full tax compliance.
