“ The primary issue in this appeal is whether SARS was correct in rejecting Purveyors’ voluntary disclosure application for non-compliance with s 227, more specifically on the ground that it was not made voluntarily. The issue therefore resolves itself into this: does the exchange or discussions between the representatives of SARS and the officials of

In its judgment on 6 March 2019 the Pretoria High Court found in favour of SARS in CSARS v Naude & others, case number 51712/2017 (not yet reported) but awarded costs against SARS for disregarding the Uniform Rules and order of the court in the course of the dispute between the applicant and SARS.  As

Recent cases argued in the tax court have increasingly focused on the Tax Administration Act, 2011 instead of on the underlying tax merits.  Taxpayers especially and to a lesser extent SARS are learning that the TAA is the essential starting point of dealings in tax matters and not merely a peripheral adjunct to the important