Professional Certificate in Tax Opinion and Dispute Writing

Date: Sep 1, 2020 - Mar 31, 2021

Application fee: R450.00

Once-off: R13,950.00

The purpose of this course is to equip the participants with the adequate skills to understand the intricacies of the Tax Administration Act (TAA) and the audit and/or dispute process. It will develop participant's critical research, problem solving and writing skills to draft TAA compliant tax opinions that will mitigate SARS penalty risk. The course will also equip participants to effectively respond to SARS letter of audit findings, prepare technical sound SARS objections and appeals.

Course overview

The course is divided into four parts (which The Tax Faculty refers to as Chunks):

  1. Understanding the Tax Administration framework,

  2. Issue identification, research and internal issue memoranda,

  3. Advisory opinions, and

  4. Controversy.

Further detail on each part is stipulated in the "what you will learn section".

Course delivery

Each part will contain a number of lecture videos and practical study notes which are available via iLearn which is The Tax Faculty’s interactive, online learning platform. This will be followed by two practical assignments and two reflective virtual classrooms to develop critical thinking skills.

Admission requirements

A minimum of BCom or LLB degree. Completed three years structured work experience in tax, accounting, law or five years unstructured experience.

Assessment and award of certificate

All participants course will be required to submit one knowledge assignment (which will take the form of a multiple choice assignment) and six practical simulation assignments to ensure that the critical thinking skills needed to accomplish the exit level outcome of each part has been attained. Participants will also be provided with a final integrative assignment when the learning from all three parts will be integrated in a practical, real live scenario.  All assignments will be independently marked with integrated feedback to prepare for the next assignment. 

Upon completion, successful candidates will receive a Professional Certificate from The Tax Faculty and 140 CPD hours. Credits may also be transferred to the SAQA accredited The Tax Professional Specialist Diploma (NQF 8).

What you will learn

  1.  Understanding the Tax Administration framework

Proper tax administration forms the heart of tax compliance. The Tax Administration Act 28 of 2011 was introduced to define the rights and responsibilities of taxpayers as well as the rights and responsibilities of the South African Revenue Service (‘SARS’).  It is important that taxpayers and tax practitioners are not only aware of their responsibilities, but also focus on what rights they have and what they are entitled to.  The Tax Administration Act is a very important tool to achieve this goal. Furthermore, the Tax Administration Act outlines the consequences of non-compliance, such as penalties that can be imposed by the SARS. 

In this chunk you will be introduced to the most important definitions, charging legislation, tax administration and record keeping requirements. These principles must be integrated with and incorporated into all the other topics and units.

  1. Issue identification, research and internal issue memoranda

This Chunk will be dedicated to the learning fundamentals associated with research. Participants need to understand the various sources of research generated by the various arms of government, such as National Treasury (tax legislation and policy), SARS (interpretation and administration) and the judiciary (interpretation). The lecture pertaining to this part of the course will be followed by two simulation assignments:

  • Assignment 2a will focus on the identification of issues.

  • Assignment 2b will expand on the compilation of internal issue memoranda.

  1. Advisory opinions

This Chunk is dedicated to opinion writing. Participants will learn how to write in terms of assessing risk as opposed to definitive conclusions. This part of the course will include discussions pertaining to the role of opinions in terms of penalties (e.g. section 223 opinions). The lectures pertaining to this chunk will be followed by an assignment where you will be required to practice your skill at opinion writing.

The opinion assignments will consist of the following:

  • Assignment 3a will entail the writing of an opinion associated with a tax return. Participants will be requested to assess the risk associated with the position as well as whether an accounting provision will be required for financial purposes.

  • Assignment 3b will be associated with an advisory opinion in terms of setting up a proposed structure. The trainee will be expected to assess various technical risks and outcome probabilities.

  1. Controversy

The last part of the course will be dedicated to the initial stages of taxpayer-SARS controversy. This process starts with the phase of initial queries and responses. These queries and responses often escalate to assessments, objections and appeals. Writing of this nature is as much about procedure as about substance. Both the relevant portions of the Tax Administration Act and the Promotion of Administrative Justice Act will be considered. The lecture to this final part will be followed by assignments relating to the various documents arising during the initial stages of tax controversy.

  • Assignment 4a will entail the writing of a response to a SARS information request and the review of a related document of SARS findings. Participants are expected to analyse information available for appropriate disclosure.

  • Assignment 4b will entail the writing of an objection to a SARS assessment as well as a corresponding request for suspension of payment. Participants are expected to defend the taxpayer’s position in terms of substance and process.

Flexible payment options

Payment option 1: Once-off payment 

R13 950.00 (incl. VAT).

Corporate discounts are available for two or more learners.

Payment option 2: Debit order

Application fee (non-refundable): R450 (incl. VAT).

Six instalments: R2 674.00 per month (incl. VAT).
Total: R16 044.00 (incl. VAT).

* First debit order will be collected on course start date. Remaining debit orders will be collected on the first day of each month.

Payments and cancellations

  • All required minimum payments must be made by direct EFT or by credit card before the commencement of a course.
  • Kindly note that should debit order payment terms not be adhered to; legal action will be taken.
  • Proof of payment may be requested before access to the iLearn platform will be communicated, should your payment not reflect on The Tax Faculty’s bank account.
  • Only written notice of cancellation will be accepted.


  • If the cancellation is requested more than 10 working days prior to the course, no cancellation fee will be applicable.
  • If the cancellation occurs less than 10 working days prior to the event a 100% cancellation fee will be applicable.
  • Students who register for a course and fail to attend will be held liable for the full course fee.
  • Course application fee is non-refundable.
  • CPD event delegates who book and fail to attend will be held liable for the full event fee.
  • The Tax Faculty’s liability in the case of a course being cancelled will be limited to a refund of the course fee.

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