Overview
Two recent High Court judgments define how far SARS may pursue a tax debt beyond the taxpayer that incurred it. In CSARS v Africa Cash and Carry (Crown Mines) (Pty) Ltd and Another, the court declared a company that took over a tax debtor's business for no consideration jointly and severally liable for that debt, of approximately R1.5 billion, and confirmed that an established tax debt is subject to the 15-year period in section 171 of the Tax Administration Act rather than the three-year period in the Prescription Act. In Cuba Dumakude v Bidvest Bank Limited and Another, the court upheld a third-party appointment issued to a bank, without a prior final demand, in respect of funds that the tax debtor had transferred into another person's account. Read together, the judgments clarify the collection exposure that practitioners must assess when advising on business transfers, related-party arrangements and the movement of funds under SARS scrutiny.
The session also examines Tax Court decisions on the timing of a capital gain realised by a trust shortly before it ceased to be resident, and on the reopening of prescribed periods under section 99(2)(a)(ii) of the Tax Administration Act, together with the SARS documents issued in the period: Interpretation Note 74 (Issue 4) on repairs, the amended Reportable Arrangement External Guide, which removes the option of requesting an advance tax ruling on an arrangement that may be reportable, and Public Notice 7958 on reduced or additional assessments following an auto-assessment.
The Monthly SARS Updates provide a two-hour analysis of legislative amendments, judgments, SARS practice and newly issued documents as they arise.
Webinar Content
Recent tax judgments
- High Court: CSARS v Africa Cash and Carry (Crown Mines) (Pty) Ltd and Another (2 October 2026): prescription of tax debts and liability of a transferee company
- High Court: Cuba Dumakude v Bidvest Bank Limited and Another (8 September 2026): third-party appointment without a final demand
- Tax Court: SARSTC IT 46306 (IT) [2026] ZATC CPT (13 April 2026): whether the transfer or migration of shares in a trust to a non-resident trust was subject to CGT
- Tax Court: SARSTC IT 45931 and VAT 22285 (ADM) [2026] ZATC DBN (23 July 2026): reopening of prescribed periods under section 99(2)(a)(ii) of the Tax Administration Act
SARS documents and notices
- Interpretation Note 74 (Issue 4): Deduction and recoupment of expenditure incurred on repairs
- Updated Reportable Arrangement External Guide
- Public Notice 7958: extended period to request a reduced or additional assessment following an auto-assessment
- 2026 Trust filing season and ITR12T enhancements
- SARS VAT modernisation
Competencies Developed
After attending this session, you will be:
- Competent to apply key aspects of newly issued SARS documents (binding rulings, interpretation notes, guides, notices, etc.).
- Competent to advise clients on the impact of the latest legislative amendments on their tax compliance obligations and planning opportunities.
- Able to train staff to prepare SARS-compliant tax returns in line with current legislation and SARS administrative practice.
- Informed about suitable topics for client communication, enabling you to alert clients to important developments affecting their tax position.
- Competent to revise client tax planning strategies based on the latest changes and emerging SARS trends.
Presenter
Professor Jackie Arendse
B Acc (Wits) M Acc (Tax) (UKZN) Chartered Accountant (SA) PhD (Accounting) (Rhodes)
After completing her training at Deloitte and qualifying as a Chartered Accountant, Jackie was Group Financial Accountant for a top-100 listed company before moving to academia where she developed her skills as an academic – authoring, lecturing, and researching on a wide range of tax areas – and also completing her master’s and PhD qualifications.
She served as Project Director: Tax at the South African Institute of Chartered Accountants (SAICA) between 2004 and 2006, managing relationships with key stakeholders (especially SARS and National Treasury), enhancing SAICA members’ tax competence and representing SAICA in discussions with government on tax policy and legislation.
Jackie was Head of the School of Accountancy at Wits University from 2009 until 2013 and was Head of the Department of Accounting at Rhodes University from 2014 until 2020. Since 2021, she has been Head of Taxation at Academic One, which is developing a fully online CTA/Accounting Honours programme, and she continues as a sought-after presenter of tax seminars and webinars.
Jackie has presented tax training to tax practitioners, accountants, small businesses, and large corporates around the country for many years and has authored numerous books, articles, and publications in the field of taxation including Silke on South African Income Tax. She is the managing author of Silke on Tax Administration, published by LexisNexis and updated annually.
CPD
Attending this webinar and the successful completion of the online assessment will secure a certificate of completion for 2 hours of Tax CPD.
Event Investment
Free for Tax Technician, Tax Practitioner, Tax Accountant CPD subscribers and Practice Packages. Not a CPD subscriber yet? Click here to register now.
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