The South African Revenue Service (“Sars”) is no longer the passive revenue service many South Africans remember. With the injection of R3.5-billion from the national budget and the ominous launch of “Project AmaBillions,” Sars has entered its most aggressive phase of enforcement in years and is quickly turning into one of the most sophisticated, assertive, and unrelenting revenue authorities in the world. Welcome to the new high-stakes era of tax compliance, which marks the end of the era of any perceived leniency, it is now the time of relentless enforcement. If you’ve received a surprise assessment or an additional tax bill, doing nothing could be financially, and legally, disastrous.

Sars Has Flipped the Switch: Compliance or Consequences

South Africa’s budget is strained, and Sars has one clear mandate: collect at all costs. The days of informal engagement are over. Today, Sars is functioning as a well-resourced enforcement agency, driven by targets and backed by increasingly automated systems that flag non-compliance in real time. Their legal tools of collection include:

• Final demands;
• Civil judgments;
• Third-party appointments issued directly to your bank without having to inform you;
• Garnishee orders issued directly to your employer;
• Instructing the Sheriff to collect;
• Asset seizures; and
• Criminal prosecution.

If you disagree with an assessment, silence is surrender. Unless formally and timeously disputed, Sars will pursue recovery. And they don’t knock, they act. From garnishee orders to default judgments, Sars is now executing collections swiftly and with minimal notice. Once the machine is in motion, it becomes significantly harder, and more expensive, to reverse.

There’s a Process - But It’s Not Forgiving

Yes, there is a dispute process. And yes, it exists to protect taxpayers, but only if used strategically and correctly. You have 80 business days from the date of assessment to lodge an objection. Miss this window, and you must beg Sars to condone your lateness, and they’re under no obligation to say yes.

Even if the assessment is plainly wrong, Sars is entitled to collect unless and until a dispute is lodged and the debt is suspended. Without this, enforcement proceeds. Your bank accounts, salary, or even those who owe you may be targeted. Sars has shown no hesitation in using every legal mechanism at its disposal, and you must thus use every legal mechanism at your disposal to protect your interests.

Disputes Must Be Strategic - This Is a Legal Battlefield

This is not the time for “DIY” tax disputes. In the enforcement era, objections need to be drafted like legal pleadings, not complaints. Sars doesn’t respond to emotion; it responds to evidence, statute, and precision. A skilled tax attorney can mean the difference between a successful objection and irreversible enforcement. This is especially critical when multiple years are at stake or where Sars alleges serious non-disclosures.

Sars Commissioner Edward Kieswetter has made their philosophy clear: compliance will be facilitated; non-compliance will be punished. The playing field may be fair, but it is also ruthless to those who don’t act timeously. 

Every Single Day Counts, and Delay Is Dangerous

In today’s enforcement climate, an assessment is not a suggestion, it’s a trigger. It signals the start of Sars’s collection clock. If you don’t respond with speed and legal force, you may find your finances, assets, and reputation under siege. Every day you delay, Sars gains ground. An assessment isn’t an invitation to negotiate. It’s a legal action, and if you fail to act swiftly and strategically, Sars will act for you - through your bank, your employer, or the courts. 

Dispute on time. Dispute strategically. Or prepare for the full force of Sars enforcement. Act now, those who wait, lose. 

Written by André Daniels, Head of Tax Controversy & Dispute Resolution at Tax Consulting SA