If you are a South African taxpayer with offshore interests, the landscape in which you operate is undergoing a fundamental shift. Increased international cooperation and enhanced domestic oversight means that the days of "offshore privacy" are largely behind us, as the South African Revenue Service (“SARS”) has strengthened its ability to detect undeclared foreign bank accounts, investments (including digital assets like cryptocurrency), and offshore asset-holding structures like companies and trusts. If you need to regularise your affairs, we propose that you consider SARS’ Voluntary Disclosure Program (“VDP”).
The Supreme Court of Appeal (“SCA”) delivered a unanimous judgment in Baseline Civil Contractors (Pty) Ltd v The Commissioner for the South African Revenue Service on 24 February 2026, providing definitive guidance on the limits of a taxpayer’s ability to amend their case during an appeal. The ruling clarifies the scope of Rule 32(3) of the Tax Court Rules, confirming that while taxpayers have some flexibility, they cannot use an appeal to introduce fundamentally new cases that target parts of an assessment never previously challenged.
The recent media ping-pong between Tshepo Lucky Montana (“Montana”) and the South African Revenue Service (“SARS”) has brought the country’s attention towards SARS’ obligation to protect taxpayer confidentiality and the very limited circumstances where SARS may disclose any information regarding taxpayers.
The postponement of the budget speech which was set to take place on Wednesday, 19 February 2025 has left the country questioning exactly what could have been in the budget that was so controversial that the speech could not go ahead but had to be postponed until 12 March 2025.
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