South Africa: Tax Authorities

Struggling to pay a significant tax debt? Learn how a compromise works, what SARS requires and why timing matters if you are disputing an assessment.

First-time provisional taxpayers often face unexpected underestimation penalties when their income streams become more complex. Understanding when these penalties apply and whether remission is possible can help taxpayers navigate compliance requirements and avoid costly mistakes when estimating taxable income.

A South African High Court has ruled on the lawfulness of account freezing by banks based on fraud suspicions and affirmed SARS's authority to issue third-party notices under section 179 of the Tax Administration Act. The case arose after a close corporation fraudulently claimed a VAT refund of R3.28 million, transferred R900,000 to an individual's account, prompting the bank to freeze the account and SARS to pursue recovery through a third-party notice.

This issue of ENS' tax in brief provides a comprehensive snapshot of recent South African tax developments, including significant High Court judgments on SARS appeals and enforcement orders, new SARS publications on documentary proof requirements and the Advance Pricing Agreement programme, and multiple customs and excise tariff amendments affecting various imported goods. The brief also covers important international developments from the OECD regarding the Global Minimum Tax implementation and corporate t

The Western Cape High Court's recent ruling in C:SARS v Meiring Citrus overturned a Tax Court decision and disallowed a ZAR9.6 million income tax deduction claimed by a citrus farmer for what was marketed as an insurance premium. The judgment raises critical questions about the distinction between genuine insurance and investment arrangements, the burden of proof in prescription cases, and the application of accounting standards to tax deductions. Taxpayers with similar structured self-insurance products sh

ENS presents issue 171 of its tax brief, covering recent South African tax developments including significant Supreme Court and Tax Court judgments on import duties, dividend stripping arrangements, and insurance contract deductions. The brief also details new SARS filing requirements, updated guides for the 2026 filing season, and important changes to customs procedures and VAT treatment of ambulance services.

On 6 February 2026, the Africa Tax Administration Forum ("ATAF") published a Technical Note summarising changes to the Global Minimum Tax ("GMT"), referred to as a "Side-by-Side Package".

The 2026 National Budget provides an important moment to assess emerging trends, policy shifts and the impact...

It is becoming increasingly unlikely that SARS will meet the collection targets required to achieve the additional R35 billion reflected in National Treasury's monthly publications.