We offer a wide range of legal services, ensuring that our team-based approach delivers innovative, practical and cost-effective solutions to our clients. With offices in Durban, Johannesburg, Cape Town, Pietermaritzburg and Richards Bay, we offer accessible and complete legal services to a diverse client base. Local and international affiliations further extend our representation throughout Southern Africa, Europe and North America.
If SARS issues an assessment and says you owe tax, they expect you to pay it — even if you believe the assessment is wrong and are challenging it in the Tax Court. For businesspeople, that can mean crippling cash flow pressure long before a dispute is resolved. In a recent Gauteng High Court judgment, Ferreria v Commissioner for SARS (Case no 2024-067035; Pretoria High Court; on 2 February 2026), is a reminder that SARS’ powers are not unlimited.
On 16 January 2026, the Constitutional Court delivered an important judgment for the fuel industry in Tholo Energy Services CC v Commissioner for the South African Revenue Service Case CCT 252/24. The decision addresses the removal of fuel levy goods (‘fuel”) to Lesotho, being a BLNE member state. Although the decision confirms that fuel levy and Road Accident Fund (RAF) levy refunds are subject to strict statutory compliance, it also applies to the refund of excise duty and levies in respect of exports to non-BLNE countries. The decision therefore provides clarity on several long-debated issues affecting cross-border fuel supplies.
Interpretation notes play an important role in the South African tax system, but they are often misunderstood. Businesses regularly encounter them when planning transactions or responding to queries from SARS, and the natural question is to what extent these documents should be followed.
A recent judgment of the Tax Court, now on appeal to the Supreme Court of Appeal (Commissioner for the South African Revenue Service v Oakleaf Investments Holdings 79 (Pty) Ltd t/a Lesedi Power Company), raises an important procedural question in South African tax litigation: to what extent may SARS reformulate its case during the appeal process without issuing a revised assessment?
Notice 3764 of 2026
Experts call for stronger enforcement of labour laws
The dangers of social media-driven impulse buying
A Career at Shepstone & Wylie
Shepstone & Wylie (S&W) will not change its banking details. Any communication you receive stating we have done so will be false - please contact us immediately.
If you bank with Standard Bank, Nedbank, Investec, FNB or Absa Bank you are encouraged to pay us using the bank approved beneficiary: Shepstone and Wylie Attorneys.
If you don’t use the bank approved beneficiary option, you must always call us to verify our banking details before making any payment.
)
