Insights & Analysis

Tax Café

Stay informed with our latest publications, case analyses, and expert commentary on South African tax law.

Pay now, argue later: time for a middle way?

The Tax Administration Act already stops SARS from collecting while a suspension request is pending. The recent judgments, and a Tax Ombud complaint open for more than eleven years, show that the protection on paper is not reaching taxpayers in practice.

21 Sept 2026

Schalk Pieterse

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Pay now, argue later: time for a middle way?

Publications

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Tax Disputes21 Sept

Pay now, argue later: time for a middle way?

Schalk Pieterse

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Tax Disputes15 Sept

Got a SARS assessment wrong? Here's when you don't need a full dispute

Picture this: SARS issues an assessment, and something on it is simply wrong: an expense added back twice, a donation receipt captured incorrectly, or a processing slip on SARS's end. Your first instinct might be to object. However, launching a formal objection has its own deadlines, forms and procedures, and if you get the process wrong, you can lose your right to challenge the assessment altogether.

Leanne Wium

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Tax Debt08 Sept

Dormant Companies And SARS Debt: The Risk Of Personal Liability

Many business owners assume that once an entity has ceased trading and become dormant, its tax affairs can simply be left unattended. Unfortunately, this can create a significant and often overlooked risk: personal liability for the entity’s outstanding SARS debt.

Wynand Neveling

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VAT01 Sept

The R2.3 Million VAT Threshold: SARS Is Applying It, But The Legislation Is Not Yet Finalised

SARS is administering a compulsory VAT registration threshold of R2.3 million and a voluntary registration threshold of R120 000 from 1 April 2026. The enacted Value-Added Tax Act 89 of 1991 has not yet been amended to reflect those amounts. Section 23(1)(a) still contains the R1 million compulsory threshold and section 23(3)(b) still contains the R50 000 voluntary threshold.

Leanne Wium & Schalk Pieterse

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Customs & Excise24 Apr

Removal In Transit: The Hidden Liability Risk For Clearing Agents

The High Court judgment in QI Logistics (Pty) Ltd v CSARS provides a clear warning to clearing agents involved in removal in transit ("RIT") transactions. These structures are widely used in practice, but the consequences of non-compliance are significant where proof of export cannot be established.

James Moolman

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Tax Disputes08 Apr

When You Change Your Case Too Late: A Hard Lesson From Baseline v SARS (2026 ZASCA 20)

As tax practitioners, we often focus on what argument to run. This judgment is a reminder that in tax litigation, the real difficulty often lies not only in what case is advanced, but in whether that case has been properly identified, framed and preserved at the correct procedural stage.

Schalk Pieterse & Chris Stroud

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Tax Compliance31 Mar

Diesel Refund Changes From April 2026: More Value, Tighter Scrutiny, And No Margin For Error

The 2025 Budget Speech introduced a targeted but important change to South Africa's diesel refund system. From 1 April 2026, qualifying on-land users in the farming, forestry, and mining can claim a refund on 100% of eligible diesel on qualifying activities.

Leanne Wium

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Tax Planning27 Mar

Section 11G: Tightening The Rules On Interest Income Deductions

The introduction of section 11G marks a deliberate shift in the taxation of passive interest structures. It follows the withdrawal of Practice Note 31, titled "Interest paid on moneys borrowed", but does not simply replicate that regime.

Karlie Venter

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