The Tax Administration and Dispute Management Technical Work Group’s Annexure C submission addresses two key issues: SARS’ practice of escalating verifications into audits without complying with section 42 of the Tax Administration Act, which undermines taxpayer rights and transparency, and the lack of a mechanism to offset tax refunds within a group of companies against additional tax liabilities of other entities, creating cash flow inefficiencies and administrative burdens. The group proposes legislative amendments to classify verifications as audits for section 42 compliance and to introduce a controlled intra-group refund set-off system, improving liquidity, compliance, and administrative efficiency while aligning South Africa with international best practice
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