Annual Tax Case Law Update 2026
Presenters : Adv Christel van Wyk
Overview
The South African tax environment in 2026 has been fundamentally reshaped by watershed judicial decisions. Legal practitioners, corporate tax teams, finance executives and advisors must contend with a heightened regulatory enforcement posture and a redefined litigation field. This focused 2-hour webinar provides an essential, practical analysis of the most critical South African tax judgments handed down in 2026, offering delegates the precise insights required to manage tax risk and structure transactions defensibly.
The session concentrates on three key pillars: the new General Anti-Avoidance Rules (GAAR) blueprint, procedural strictness and pleading restraints in Tax Court appeals, and the requirements of administrative fairness in SARS disputes. From the Constitutional Court's landmark ruling on GAAR boundaries to Supreme Court of Appeal decisions regulating procedural bounds, this webinar unpacks how the judiciary is balancing SARS' enforcement powers against taxpayers' constitutional rights.
We invite you to join our upcoming Annual Tax Case Law Update webinar hosted by Advocate Christel van Wyk as she untangles all these complex developments, equipping you to manage your professional liability and advise your clients or board with absolute confidence.
Learning objectives
Attending this webinar will equip you with the following skills:
- Evaluate the expanded reach of General Anti-Avoidance Rules (GAAR) following the Constitutional Court's decision in Absa Bank Ltd and Another v CSARS [2026] ZACC 15
- Assess how the "Absa counterfactual approach" is applied to dividend-stripping arrangements under Company AF (Pty) Ltd and Others v CSARS [2026] ZATC 6
- Mitigate risk of procedural default by aligning objection and litigation strategies with the pleading limits affirmed in CSARS v Erasmus [2026] ZASCA 22
- Formulate defensible Tax Court pleadings under Rule 32 of the Tax Court Rules, respecting the limits on introducing new objections set in Baseline Civil Contractors (Pty) Ltd v CSARS [2026] ZASCA 20
- Defend client interests during tax disputes by leveraging the transfer pricing and pleading precedents established in BASF South Africa (Pty) Ltd v CSARS [2026] ZAGPJHC 275
- Enforce procedural rationality and administrative justice in customs and excise disputes under the principles of QI Logistics (Pty) Ltd v CSARS [2026] ZASCA 96
Content
The webinar will cover the following topics:
● Part 1: GAAR & corporate anti-avoidance
○ Absa Bank Ltd and Another v CSARS [2026] ZACC 15
○ Company AF (Pty) Ltd and Others v CSARS [2026] ZATC 6
● Part 2: Procedural strictness & pleading restraints
○ CSARS v Erasmus [2026] ZASCA 22
○ Baseline Civil Contractors (Pty) Ltd v CSARS [2026] ZASCA 20
○ BASF South Africa (Pty) Ltd v CSARS [2026] ZAGPJHC 275
● Part 3: Administrative fairness & dispute rules
○ QI Logistics (Pty) Ltd v CSARS [2026] ZASCA 96
● Part 4: Tax deductions & VAT mechanics
○ CSARS v Meiring Citrus (Pty) Ltd [2026] ZAWCHC (26 June 2026)
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- Taxpayer Bank Limited v CSARS [2026] ZATC