ARTICLE · 23 FEBRUARY 2022

The Nitty Gritty Of SARS' Voluntary Disclosure Programme

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The Tax Administration Act, 2011 ("TAA") allows a taxpayer to approach the South African Revenue Service ("SARS") to "come clean"

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Cameron Nathaniel

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The Tax Administration Act, 2011 ("TAA") allows a taxpayer to approach the South African Revenue Service ("SARS") to "come clean", provided all the relevant requirements are met. In particular, the requirements for a valid application in terms of the "voluntary disclosure programme" ("VDP") in terms of section 227 of the TAA are that the disclosure must:

be voluntary;
involve a "default" that has not occurred within five years of the disclosure of a similar "default" by, inter alia, the applicant;
be full and complete in all material respects;
involve certain behaviours referred to in the understatement penalty provisions;
not result in a refund due by SARS; and
be made in the "prescribed form and manner."

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