02/09/2026
In this personal income tax dispute, the merits were finely balanced. Our approach therefore considered the numbers, the law and the legality of the process followed by SARS, including accountability where proper procedure was not followed.
Tax administration is not a courtesy extended to taxpayers. It is a body of law that binds the administrator.
Each material procedural departure was identified and formally recorded. SARS was given the opportunity to correct these issues. Where it did not, those procedural defaults became litigation exposure — materially changing the settlement landscape.
But securing a settlement is only part of the process. A settlement is worth little until it is correctly implemented.
James Moolman from our Cape Town office remained in command of the file from the first letter through to the final journals being processed, ultimately ensuring that the taxpayer’s account reflected a nil balance.
Precise strategy. Relentless ex*****on. A decisive result.
TRM Tax Attorneys.
Schalk Pieterse
Eddie Sellner
Wynand Neveling
Leanne Wium
Rudi Stander
