The resolution of tax disputes in South Africa has changed fundamentally over the last few years and there is now much to consider as a taxpayer, or when doing business, in the country.
Changing climate

Co-head of tax department
Edward Nathan Sonnenbergs
Not long ago, if a taxpayer received a query or assessment from the South African Revenue Services (SARS), it would approach its lawyer or accountant and ask for assistance. The taxpayer’s lawyer or accountant would generally submit a brief response on behalf of the taxpayer, maybe attend a meeting or two with SARS, and often the matter was simply and easily resolved.
Now SARS is a properly staffed and effective business focused on ensuring that it meets its annual budget. SARS, like any business, is under budgetary pressure, particularly in these recessionary times.
In addition, tax law is complex and ever-changing. This combined dynamic gives rise to a significant number of tax disputes which are no longer capable of simple resolution through a series of correspondence and perhaps a few meetings with SARS.
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Peter Dachs is co-head of the tax department at Edward Nathan Sonnenbergs

Johannesburg
150 West Street
Sandton
Johannesburg
South Africa
2196
Tel: +27 11 269 7600
Fax: +27 11 269 7899
E-mail: info@ens.co.za