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Tax disputes: why they no longer belong solely to the accounting profession

The Star

|

October 24, 2025

FOR years, I've maintained that tax disputes do not sit comfortably within the accounting profession.

- WILLEM J. OBERHOLZER

The latest wave of Sars (South African Revenue Services) enforcement proves exactly why.

Tax has become more legal than numerical. The days when an accountant could file an objection by simply completing a form and attaching a few schedules are over. Sars has become procedurally aggressive - and unapologetically so. Every technicality is now an opportunity to reject, delay, or disallow. If you miss a step, you lose. And that loss isn’t academic; it’s financial.

South Africa’s fiscal position has tightened dramatically. Treasury's debt service costs are ballooning, growth is stagnant, and the political space for tax increases is gone. Sars is under immense pressure to deliver more with less, so it's focusing on procedural enforcement to close the collection gap.

That means process is the new battleground.

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