Tag: tax assessment

A recent Gauteng High Court judgment has brought clarity on the interaction between consolidation orders under the Companies Act and the South African Revenue Service’s (SARS) powers to raise tax assessments. In Prinsloo and Others N.O. vs CSARS and Another (020214-2023) [2025] ZAGPJHC (29 August 2025), the court quashed an attempt by liquidators to set aside SARS assessments against a Ponzi scheme.

In its drive to meet the ambitious 2025/26 revenue estimate of R1.986 trillion, the South African Revenue Service (SARS) has made its expectations clear. Timely, transparent and accurate tax submissions are now the new normal. Central to this approach is the expanded use of third-party data. This applies broadly, including trusts and Non-Profit Organisations (NPOs).

All taxpayers should arrange their tax affairs to obtain the best advantage and to pay the least amount of tax. This is a right every taxpayer possesses, and well entrenched in South African and international tax law. However, this planning must be done within the constraints of what the law allows.

Speak to any individual taxpayer and tax practitioner these days and no doubt ‘auto assessments’ will feature in the conversation. Whilst many agree that the auto assessment process is a good idea and there is appreciation of SARS’ intention to simplify tax compliance, there are mixed feelings regarding the implementation and practicality thereof.

A taxpayer who disputes a tax assessment has processes available in the Tax Administration Act, 2011 (Act) to contest the assessment. It is sheer folly for a taxpayer who contests an assessment not to avail himself of the mechanisms in the Act timeously.

Tax is the price we pay for civilisation and transfer pricing is the price we pay for globalisation. Over the years, transfer pricing has...