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CONCOURT ON BONA FIDE INADVERTENT ERROR AND USP’s
The eagerly anticipated Constitutional Court judgment in Thistle case[1] has been delivered. Unfortunately, though, the court did not consider the meaning of the words “bona fide inadvertent error” because the court did not grant SARS leave to cross-appeal the judgment of the SCA insofar as USP’s are concerned. The question then is, where does that…
TRUSTS ENTER THE SECTION 210 TAX PENALTY REGIME: MORE EXPANSION THAN REVOLUTION
There has been a great deal of noise about SARS’ trust penalties. On my reading, the real story is both simpler and more significant. SARS has not invented a new penalty. It has extended an old section 210 mechanism to a new class of taxpayer — trusts — at a time when revenue collection and…
ESTIMATED ASSESSMENTS: FROM EXCEPTION TO CASH-COW GRABBING NORM?
SARS can, in terms of section 95(1)(b) of the Tax Administration Act, 2011 (TAA) raise an assessment based on an estimate if the taxpayer submits information to SARS that is either incorrect or inadequate. How SARS often prepare these estimates is by comparing deposits into the taxpayer’s bank account to turnover declared on the tax…
YES, YOU REALLY CAN MESS UP A SARS OBJECTION!
For a detailed further video explanation see my video on our Youtube Channel – Click Here The judgment of the Western Cape Tax Court in the matter of DR X and Dr X Inc v CSARS[1] (“the Dr X case”) appears to be a good example to explain how it is possible to screw up…
TAXPAYERS BEWARE: SARS’ INDEFINITE EXTENSION
On 4 June 2025, the SCA ruled[1] that SARS is not required to request condonation if they remedy their default within the 15-day notice period contemplated in rule 56(1) of the Tax Court Rules (“the rules”) gazetted under section 103 of the Tax Administration Act 2011 (“the TAA”). What this means, practically speaking, is that…
THE PARADOX OF VOLUNTARY DISCLOSURE: AI, SARS, AND THE FEAR FACTOR
In an era defined by rapid technological advancement, the concept of “voluntary disclosure” is experiencing a seismic shift. Taxpayers, who once viewed the opportunity to come forward and declare financial irregularities to the South African Revenue Service (“SARS”) as an empowering choice, are now faced with a pressing dilemma: Are these disclosures genuinely voluntary, or…
