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Tax Audits and Dispute Resolution

Tax Law Seminar
Where Inanda Greens Office Park, Building 2
54 Wierda Road West
South Africa
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The South African Revenue Service (“SARS”) conducted close to 2 million tax audits during 2014 of which approximately 20,000 were "high-risk, complex and high-impact" matters. It is crucial that taxpayers that are the subject of an audit understand their rights and the scope of SARS powers. Without a good understanding of these rights a taxpayer’s actions during the audit process can end up being prejudicial to its case should the matter end up in Tax Court.


Where an audit finding results in an additional or revised assessment being issued by SARS the taxpayer is entitled to object to the assessment and where SARS rejects the objection the taxpayer can then appeal to the Tax Court. The Supreme Court of Appeal has found that the taxpayer’s failure to raise an issue in its notice of objection precludes it from then raising it on appeal before the Tax Court. It is essential therefore that taxpayers are aware of the provisions of the new Tax Court rules, in particular the relevant time restrictions and the content of an objection.


In light of the uptake in audits being carried out by SARS, recent legislative amendments relating to audits and the introduction of new Tax Court rules the seminar will cover:

  • The audit process and the taxpayers rights during the process including:
    • field audits, inspections and requests for relevant materials by SARS;
    • legal professional privilege relating to taxpayers materials;
    • procedural fairness;
    • recent case law; and
    • the relevant 2015 amendments to the Tax Administration Act that came into effect on 8 January 2016, including the amendments that now allow for SARS to interview and obtain materials from employees of the taxpayer.
  • Objecting to and appealing an assessment to the Tax Court  including:
    • an overview of the new Tax Court rules;
    • alternative dispute resolution as an option;
    • recent case law;
    • requesting suspension of payment of taxes pending appeal;
    • costs; and
    • further appeals.


  • 08h30 - 09h00 Registration and Breakfast
  • 09h00 - 11h00 Presentation