Overview 

Drafting a technically accurate, legally sound and professionally structured tax opinion is a critical skill for today's tax practitioners and advisors. As South African tax legislation grows more intricate and SARS intensifies its audit scrutiny, taxpayers require strategic, evidence-based guidance. Providing high-value transactional advice demands that practitioners conduct exhaustive legal research, analyse complex statutory provisions, and articulate defensible conclusions with absolute clarity. 

A poorly formulated or poorly researched tax opinion exposes the practitioner to substantial professional indemnity risks and leaves clients vulnerable to severe tax penalties and interest. Tax advisors must know how to construct opinions that serve as reliable shields during disputes or audits. This requires a systematic understanding of the hierarchy of tax law, proper evidentiary weighting of legal authorities, and the practical distinction between standard tax advice, a "more-likely-than-not" opinion, and an expert opinion. 

Join Adv. Christel van Wyk on 28 August 2026 from 10h00 to 12h00 as she conducts this practical, interactive workshop on tax opinion writing. Designed specifically for legal and tax professionals, this session unpacks the essential mechanics of researching, structuring, and writing defensible tax opinions that comply with legal, ethical and professional standards.  

Learning objectives 

Attending this webinar will equip you with the following skills: 

• Understand the key elements and structural framework of a professionally drafted tax opinion. 

• Conduct targeted and authoritative tax research using recognised methodologies. 

• Distinguish between primary and secondary sources of tax law and evaluate their evidentiary value. 

• Prepare both a more-likely-than-not opinion and an expert tax opinion based on relevant legal authority. 

• Strengthen written communication skills to deliver clear, practical and client-focused tax advice 

 Content 

The webinar will cover the following topics: 

• Part 1: Introduction to Tax Opinion Writing  

  • Purpose and role of tax opinions  

  • Professional responsibilities of the tax advisor  

  • Characteristics of an effective tax opinion  

• Part 2: Key Elements of a Tax Opinion  

  • Structuring a tax opinion  

  • Identifying material facts  

  • Legal analysis and application  

  • Developing reasoned conclusions  

  • Professional presentation and formatting  

• Part 3: Tax Research Methodologies and Sources  

  • Tax research methodologies  

  • Primary sources of tax law  

  • Secondary sources of tax law  

  • Legislative interpretation  

  • Evaluating legal authority  

• Part 4: Specific Tax Opinion Topics  

  • More-likely-than-not opinions  

  • Expert tax opinions  

  • Risk assessment and defensible conclusions  

• Part 5: Practical Examples  

  • Practical drafting exercises  

  • Case-based examples  

  • Common drafting errors and best practices  

  • Client-focused communication techniques  

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 

• R 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]