Recent court case on the imposition of understatement penalties

The Supreme Court of Appeal (“ZASCA”) delivered a judgment[1] on 26 February 2019 on the imposition of understatement penalties as provided for in the Tax Administration Act[2]. In this case, the taxpayer paid provisional income tax (“IT”) of R13.8 million to the South African Revenue Service (“SARS”) for the 2011 to 2014 years of assessment. […]