The inherent complexity of fiscal legislation makes tax law a highly specialised area of practice. The challenges posed by tax law are compounded by routine changes to tax legislation and increased enforcement by SARS in recent years. In this environment, it is critical to seek integrated, up-to-date, tax advice under the protection of legal professional privilege. Our tax & exchange control practice deals with a wide variety of matters that cover all tax types. We provide planning, advisory and transaction related services and our tax team is actively involved in dispute resolution and engagements with SARS.
Approval for inbound and outbound transactions and investments.
Engagement with Authorised Dealers and the Financial Surveillance Department of the SARB.
Opinions, Advance Rulings and Tax Directives
Compile and submit applications for advanced ruling from SARS to procure transactional certainty.
Provide general tax opinions on the tax treatment of structures, transactions and agreements.
Drafting tax opinions for purposes of section 223(3)(b) of the Tax Administration Act.
Procuring private opinions from SARS to obtain guidance on various tax matters.
Obtaining optimised tax directives on share vesting and lump sum payments.
SARS DISPUTE RESOLUTION AND ENGAGEMENT
Dispute Resolution
Responding to verification requests and SARS audits
Drafting of requests for suspension of disputed tax debts
Penalty abatement requests
Preparing objections and appeals
Representation in Alternative Dispute Resolution
Tax litigation
Settlement negotiations with SARS
Voluntary Disclosures
Compiling and submission of voluntary disclosure applications to regularise historic non-compliance in terms of the Voluntary Disclosure Programme under the Tax Administration Act.
Tax calculations and support
Responding to queries and liaising with SARS
Tax Debt Management
Drafting and negotiation of applications for tax debt reductions.
Negotiation of payment plans
Tax Administration
Reversal of irregular tax debt collection
Recovery of delayed VAT refunds
Expedited issuance of tax compliance certificates
Enforcement of prescribed time periods on SARS engagements and disputes
