SARS Disputes

Audits, objections, appeals and voluntary disclosure, handled strategically and on time.

Disputes with SARS follow a strict process under the Tax Administration Act. Missing a deadline can leave you with an assessment you cannot challenge. Early, well-prepared engagement often leads to a better outcome.

Where we assist

  • Audits and verifications: responding to requests for information and audit findings.
  • Requests for reasons: asking SARS to explain an assessment before objecting.
  • Objections and appeals: challenging assessments, penalties and interest.
  • Suspension of payment: asking SARS to suspend payment of disputed tax while the dispute runs.
  • Voluntary disclosure: regularising your affairs before SARS takes action.

Pay now, argue later

Disputed tax is generally payable even while you object or appeal. You can request suspension of payment, which SARS considers based on factors such as the risk to collection and the merits of the dispute.

Voluntary Disclosure Programme

If you have undisclosed income or tax defaults, the VDP may provide relief from understatement penalties and criminal prosecution, but only if you apply before SARS has notified you of an audit or investigation into the matter.

Who we help

We assist:

  • Individuals and businesses facing SARS audits.
  • Taxpayers who received an unexpected assessment.
  • Companies with VAT, PAYE or income tax disputes.
  • Directors facing personal liability for company tax debts.
  • Taxpayers with undisclosed offshore income or crypto gains.
  • Businesses negotiating payment arrangements with SARS.

The dispute process

From assessment to resolution.

  1. Request for reasons
    If the basis of an assessment is unclear, a request for reasons can be made within the prescribed period.
  2. Objection
    A formal objection is lodged within the prescribed period, setting out the grounds in detail.
  3. Appeal
    If the objection is disallowed, an appeal can be lodged to the Tax Board or Tax Court.
  4. Alternative dispute resolution
    Many appeals can be resolved through ADR with SARS, which is less formal and less costly.
  5. Tax Court
    Unresolved appeals are heard by the Tax Board or Tax Court, with further appeals to the High Court and Supreme Court of Appeal.

We work alongside your accountant or tax practitioner, bringing the legal and litigation expertise needed when a dispute escalates.

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What to prepare

Documents that help us assess your dispute.

  • The assessment and any SARS letters or audit findings.
  • Your tax returns for the relevant periods.
  • Supporting financial records and contracts.
  • Correspondence with SARS.
  • Details of any deadlines already running.

Common Questions

Strict time limits apply under the Tax Administration Act and its rules, and late objections are accepted only in limited circumstances. Get advice as soon as you receive an assessment.
Generally yes, unless SARS agrees to suspend payment. A suspension request should be made early, together with the request for reasons or objection.
In certain circumstances, yes. Directors and other responsible persons can be held personally liable for a company’s tax debts, for example where they were negligent or fraudulent in its tax affairs.
The Tax Board hears appeals below a monetary threshold and is less formal. The Tax Court hears larger and more complex disputes and its proceedings are more formal.
Not for the same matter if you have been notified of an audit or investigation into it. The application must be voluntary.

IN A DISPUTE WITH SARS?

We help taxpayers challenge assessments, negotiate with SARS and regularise their tax affairs, protecting their rights at every stage.

Read more: Directors’ personal liability for company tax debts

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This page is general information and not legal advice.

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