
Tax amendments materially narrow understatement penalty defence
The bona fide inadvertent error defence is limited to substantial understatements, but there is relief for taxpayers seeking to challenge estimated assessments.

The bona fide inadvertent error defence is limited to substantial understatements, but there is relief for taxpayers seeking to challenge estimated assessments.

The proposal restricts the ‘bona fide inadvertent error’ defence under the understatement penalty regime to cases where the tax shortfall is a ‘substantial understatement’.

Half of corporate taxpayers in PwC’s latest survey express dissatisfaction with SARS’s service improvements. Only 3% report a positive shift, while audit delays and penalty disputes remain a major pain point.

Expert legal interpretations, even if contrary to SARS’s stance, may not automatically result in understatement penalties.