Professional Certificate in Tax Opinion and Dispute Writing

Date: Feb 22, 2023 - Aug 22, 2023

Application fee: R1,950.00

Once-off: R21,950.00

Lecturer: Johan Heydenrych CA(SA)

The purpose of this short learning programme (SLP) is to equip the learners with the adequate skills to understand the intricacies of the Tax Administration Act (TAA) and the audit and/or dispute process. It will develop learner's critical research, problem solving and writing skills to draft TAA compliant tax opinions that will mitigate SARS penalty risks.

Please see full course payment breakdown below.

The course will also equip learners to effectively respond to SARS letter of audit findings, prepare technical sound SARS objections and appeals.

Course overview

The SLP is divided into four parts:
  1. Understanding the tax administration framework.
  2. Issue identification, research, and internal issue memoranda.
  3. Advisory opinions.
  4. Controversy.
Further detail on each part is stipulated in the "what you will learn section".

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 (TAA) is a very important tool to achieve this goal. Furthermore, the TTA outlines the consequences of non-compliance, such as penalties that can be imposed by SARS. 

In this section, 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 section will be dedicated to the learning fundamentals associated with research. Learners 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 section is dedicated to opinion writing. Learners 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. Learners 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. Learners 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. Learners 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.

Admission requirements

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

Mode of 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 videos to develop critical thinking skills.

Course duration

6 months.


This course is presented as a SLP by The Tax Faculty (TTF). TTF is accredited as a continuous professional development (CPD) provider by the South African Institute of Taxation (SAIT), a South African Revenue Services Recognised Controlling Body (RCB) under the Tax Administration Act, 2011 (Act No 28 of 2011).

TTF is registered as a skills development partner (SDP) under the Skills Development Act, 1998 (Act No 97 of 1998) by the Quality Council for Trades and Occupations (QCTO).

Assessment and award of certificate

All course participants 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-life scenario. All assignments will be independently marked with integrated feedback to prepare for the next assignment. 

Learners are assessed via a number of formative and summative assessments. Successful learners will receive a SLP certificate issued by The Tax Faculty. This SLP certificate is non-credit bearing, however, successful learners articulating into the Occupational Certificate: Tax Technician (NQF 6) programme, will obtain recognition for prior learning (RPL) towards the NQF 6 qualification. In addition, this just-in-time learning programme also qualifies for verifiable CPD.

Flexible payment options

Payment option 1: Once-off payment 

R21 950.00 (incl. VAT).

Corporate discounts are available for two or more learners.

Payment option 2: Debit order

Application fee (non-refundable): R1 950.00 (incl. VAT).

Six instalments: R3 850.00 per month (incl. VAT).
Total: R25 050.00 (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. The once-off payment is required to be paid before the course start date, as well as the application fee of learners on a debit order plan (the first debit order is also required on the start date of the course).
  • Kindly note that should debit order payment terms not be adhered to; legal action will be taken and access to the online learning platform suspended.
  • Proof of payment may also 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.

For all short learning programmes (SLPs) with a seven-month or less rollout period, the following will apply:

  • If the cancellation is requested more than 10 working days prior to the course start date, no cancellation fee will be applicable.
  • If the cancellation occurs less than 10 working days prior to the course start date, 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.
  • The course application fee is non-refundable.
  • The Tax Faculty’s liability in the case of a course being cancelled will be limited to a refund of the course fee.
  • Students who have failed to successfully complete the course, and wishing to repeat will be charged the full course fee to repeat.

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