SARS Penalty Dispute: Why the Correct Remedy Matters
A SARS penalty dispute is not won by irritation, indignation or a well-written explanation alone. The first issue is procedural: what penalty has SARS imposed, what decision is being challenged, and which remedy does the Tax Administration Act make available? Unicus approaches these matters as tax dispute problems, not routine correspondence, because the correct route […]
SARS Audit Assistance for High-Stakes Tax Matters
SARS audit assistance becomes critical when an audit is no longer a routine document request but a possible tax dispute in the making. If you have received a SARS audit notice, a SARS verification request or a SARS letter of findings in a material matter, your response must do more than answer the immediate query. […]
SARS Tax Appeals: Strategy After a Disallowed or Partly Allowed Objection
A SARS tax appeal becomes relevant when an objection has been disallowed or only partly allowed, and the taxpayer must decide how to move the dispute forward. At this point, the issue is no longer simply whether SARS is wrong. The practical question is how the case should be positioned, evidenced and advanced so that […]
SARS Objection: The First Step in Challenging an Assessment
Do Not Treat the Objection as Admin If SARS has issued an assessment, audit outcome or decision that you believe is wrong, a SARS objection is the first serious move in the dispute. It is not merely a form to submit before the deadline. It is where the grounds, evidence and strategy begin to take […]
Consulting for Complex SARS and Tax Law Problems
Not every tax question needs specialist tax consulting. Serious SARS problems do. Once the matter involves a disputed assessment, a material penalty, a refund dispute or an uncertain interpretation point, the taxpayer needs a strategy that protects the position from the start. A serious SARS problem needs a strategy, not a guess. Unicus Tax Specialists […]
Voluntary Disclosure Programme Applications: Strategy Before Submission
A Voluntary Disclosure Programme application is often considered when a taxpayer discovers a tax default and wants to correct the position before the matter escalates with SARS. Used correctly, it can be a powerful route. Used without proper analysis, it can expose the taxpayer to avoidable risk, unnecessary cost and a poorly framed engagement with […]
Tax Dispute Resolution in South Africa: What Taxpayers Need to Know Before Taking SARS On
A SARS dispute is not an admin inconvenience when the numbers are high, the facts are complicated or time is running out. Tax dispute resolution South Africa taxpayers face is a formal process, and early strategy can protect the taxpayer’s position before the matter moves into objection, appeal, ADR or court. The real question is […]
It’s Never Just Timing: The Deduction Risk Hiding in the Wrong Tax Year
A Tax Court judgment on a wrong-year deduction highlights the risks of timing errors, section 11(a), VAT section 23C, reduced assessments and whether earlier years can still be corrected.
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 […]
SARS’ Allocation Game – Interest After Payment
When a VAT dispute is settled and paid, can SARS still keep capital alive and charge interest? The Full Court in Inhlakanipho says: not so fast.