The prescription rules of the Tax Administration Act provide taxpayers with finality of assessments after a prescribed period of time. These periods are however not absolute. The Supreme Court of Appeal recently considered the application of the exceptions that preclude the prescription periods from applying. The judgment in C:SARS v Spur Group (Pty) Ltd (Case no 320/20) [2021] ZASCA 145 (15 October 2021) is a reminder to taxpayers of the importance of completing tax returns accurately and implementing proper controls in this regard.
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