Overview 

Understatement penalties remain one of the most contentious areas of South African tax administration and dispute resolution. With SARS placing increased focus on compliance enforcement, legal and tax practitioners must understand the principles underpinning the understatement penalty regime, the practical interpretation of behavioural categories, and the burden of proof required when disputing penalties. Recent legislative amendments and important court decisions have further shaped the application of these provisions, making it essential for practitioners to remain informed and equipped to advise clients effectively. This webinar will provide attendees with a practical and technical understanding of understatement penalties, including dispute strategies, procedural considerations, and the interpretation of relevant legislative provisions. 

Join Christel van Wyk on 30 June 2026 from 10:00 am to 12:00 pm as she explores the understatement penalty regime, recent case law developments, and practical dispute strategies to assist practitioners in managing compliance risks and strengthening client advisory services. 

Learning objectives 

Attending this webinar will equip you with the following skills: 

• Gain an overview of the understatement penalty regime and its practical application  

• Identify how understatement penalties may impact clients and their businesses  

• Formulate detailed and effective dispute grounds against understatement penalties  

• Recognise the underlying requirements of relevant legislative provisions and burden of proof principles  

• Evaluate and prepare client service deliverables in line with current understatement penalty requirements 

Content 

The webinar will cover the following topics: 

• Technical Analysis of the Understatement Penalty Provisions 
  o Broad overview of the understatement penalty regime 
  o Practical analysis of legislative definitions 
  o Behavioural categories and their application  

• The Relevance of the Onus Provisions 
  o Section 102(2) of the Tax Administration Act (TAA) 
  o Burden of proof in civil tax matters 
  o Practical examples and evidentiary considerations  

• Case Law Developments in a Nutshell 
  o Recent Constitutional Court judgments 
  o Judicial interpretation of understatement penalties 
  o General approach adopted by the courts  

• Practical Pointers and Dispute Strategy 
  o Practical real-life dispute examples 
  o Common pitfalls to avoid when disputing understatement penalties 
  o Guidance on effective penalty dispute strategies 

About the presenter 

Adv Christel van Wyk 

Christel van Wyk is a General Tax Practitioner (SA) and a practicing Advocate in the Northern Cape, registered with The South African Institute of Taxation. With over 25 years of experience in both legal and tax fields, her expertise spans corporate international tax, tax avoidance, dispute resolution, and policy work. She has held key positions in both the private and public sectors, serving as a legal advisor to an international bank and a property company, and later leading significant roles at SARS, EY, SAICA, and the Office of the Tax Ombud. 

Christel's broad experience includes legislative submissions, tax dispute strategy, and heading various tax-related divisions. In 2023, she founded her own tax and legal practice. Academically, she holds a BA Law degree from the University of Stellenbosch, an LLB from UNISA, a Diploma in Taxation from the University of Johannesburg, and a Certificate in Mediation and Arbitration. 

Who should attend? 

The following persons will benefit from attending this webinar: 

• Advocates. 

• Attorneys. 

• Corporate Legal Professionals. 

• Legal academisc. 

• Candidate attorneys. 

• Law students. 

• Paralegals. 

Price 

•   450.00 - Online admission - Individual.  

• Group Price 1 - From R337 per person (up to 5 users)   

• Group Price 2 - From R260 per person (up to 10 users)   

• Group Price 3 - From R224 per person (over 11 users)  

Steps to register for the event:  

If you already have a profile, login and register for the webinar. 

If you don’t have a profile, create a free profile then login and register for the webinar. 

Click here  to create a free profile (There is no charge to create a profile and gain access to our free Monthly Practice Management Series). 

Click here  to find out about the Technical Resource Centre & CPD Subscription options. 

Additional material 

By attending this webinar you will be provided with: 

• A summarised slide presentation. 

• Reference documents and/ or course material where available. 

• You can ask questions during the webinar and you will also have access to the presenter after the webinar. 

About SA Legal Academy 

Welcome to SA Legal Academy (SALA), a provider of courses to help you succeed in your chosen career. We are committed to providing our students with the highest quality training and support, to ensure that your skills and knowledge are up to date and ready to face the challenges of the modern workplace. Our courses are designed to ensure that you reach your professional goals and enhance your career prospects. With our experienced training staff and comprehensive resources, you can be confident that you will receive the highest quality of training from SA Legal Academy. 

SALA is a Level 2 B-BBEE contributor, with 125% procurement recognition. Training spend on certain solutions can be allocated against the Skills Development element of the B-BBEE Scorecard through accredited and nonaccredited training or claimed through SETA grants. In addition, 25% of your Skills Expenditure can be claimed on non-accredited training or courses. 

Corporate Training Solutions 

At SALA, we recognize the evolving needs of businesses in today's dynamic environment. Beyond our standard webinar offerings, we provide tailored corporate training solutions designed to empower your team with the latest in legal and professional skills. Whether you're looking for online sessions or face-to-face training, our programs are crafted to ensure a comprehensive and engaging learning experience. 

Drawing inspiration from modern training methodologies, our corporate solutions are interactive, adaptable, and focused on real-world applications. We prioritize hands-on learning, ensuring your team can immediately apply their newfound knowledge in practical scenarios. 

Interested in a bespoke corporate training experience? Reach out to us at [email protected] or call 012 941 0448. Together, let's design a training program that elevates your team's capabilities and aligns with your organizational goals. 

Contact Us For More Information 

Have any questions or need any assistance? Contact us today!  

• Online chat through our website.  

• Phone: +27 (0) 12 941 0448  

• E-mail: [email protected]