IN THE TAX COURT OF SOUTH AFRICA
[HELD AT MEGAWATT PARK]
(1) REPORT ABLE : NO
(2) OF INTERE ST TO OTHER
JUDGE S: NO
(3) REVISED. ~
DATE: }il/ 3/'U:> 2 C,
In the matter between:
FIRSTRAND BANK LIMITED
and
THE COMMISSIONER FOR THE SOUTH AFRICAN
REVENUE SERVICE
JUDGMENT
The judgment and order are published and distributed electronically.
CASE NO.: VAT32666
Appellant
Respondent
2
Summary: Appeal in terms of section 107 of Tax Administration Act against the disallowance of
the Taxpayer 's deduction of input VAT in terms of section 21(2) of the VAT Act. Dispute related to
whether banking fees previously debited and thereafter credited to accounts of clients in terms of
a "cash back scheme" initiated by Taxpayer to increase/protect market share in credit provision
market falls under the provisions of section 21 (l)(c) of the VAT Act. SARS argued that there are in
essence two distinctly separate transactions and that the second transaction (crediting of the
client 's account when certain criteria are met) constitutes a service rendered by the client
(complying with the qualifying criteria) for which the client is then paid by the Taxpayer and is
thus not a credit note event. Held that the argument advanced by SARS was conflated. The
jurisdictional requirement for triggering section 21(/)(c) of the VAT Act (a previously agreed
consideration altered by agreement, either as a discount or for any other reason) is a purely fac tual
enquiry and the evidence to be considered wholistical/y. Appeal upheld.
PA VAN NIEKERK , J
INTRODUCTION :
(1] This is an appeal in terms of section 107 of the Tax Administration Act 28 of 2011 ("T AA")
against a decision of the Respondent. Appellant is FirstRand Bank Limited ("the Taxpayer"),
a company duly incorporated in terms of the laws of the Republic of South Africa which
provides banking and associated services through divisions inter alia known as "First
National Bank", "Wesbank", and "Rand Merchant Bank". The Taxpayer is a company within
the FirstRand Group.
(2] Respondent is The Commissioner for the South African Revenue Service (" SARS'). The
appeal is against a decision of SARS to disallow an amount of RS 551 275.52 which the
Taxpayer deducted as input tax in respect of Value Added Tax ("VAT) for the tax period
August 2020 to July 2021 ("the disputed tax period').
BACKGROUND TO THE APPEAL :
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[3] On 4 October 2022 SARS issued a Finalisation of Audit Letter and additional VAT
assessments to the Taxpayer in relation to the disputed tax period in terms of which SARS
disallowed the amount referred to supra which the Taxpayer deducted in the disputed tax
period. On 21 October 2022, pursuant to the aforesaid decision to disallow the deducted
amount ("the decision"}, the Taxpayer lodged an objection which was disallowed by SARS
on 1 June 2023. The Taxpayer thereafter submitted a notice of appeal against the decision
on 9 June 2023, whereafter SARS filed its Statement of Grounds of Assessment in terms of
Rule 31 on 31 January 2024. In the notice of Appeal, the Taxpayer seeks an order upholding
the Appeal with relevant ancillary relief, and in the alternative, the Appellant seeks relief in
respect of penalties levied by SARS.
[4] The appeal was set down before this court, duly constituted in terms of section 118 of the
Tax Administration Act, consisting of a judge and two members. The matter was set down
for hearing from 16 March 2026 to 20 March 2026, but the appeal was concluded on 18
March 2026 after only one witness was called by the Taxpayer. After cross-examination of
the witness by the legal representative of SARS, both the Taxpayer and SARS closed their
respective cases.
THE ISSUES IN DISPUTE :
[5] In a joint practice note filed by the parties, the nature of the dispute was formulated as
follows:
"5.1 The dispute relates to sections 21(1){c) and 21(2)(b) of the Value-Added Tax Act 89 of 1991
('VAT Acr), which state:
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'(1) This section shall apply where, in relation to the supply of goods or services by any
registered vendor,
(c) the previously agreed consideration for that supply has been altered by
agreement with the recipient, whether due to the offer of a discount or for
any other reason and the supplier has -
(i) provided a tax invoice in relation to that supply and the amount shown
therein as tax charged is incorrect in relation to the amount properly
chargeable as a result of the above-mentioned events, the supplier shall
provide the recipient with a credit note; or
(iij furnished a return in relation to a tax period in respect of which output tax
on that supply is attributable, and has accounted for an incorrect amount of
output tax on that supply in relation to the amount properly chargeable on
that supply as a result of the occu"ence of the above-mentioned event'.
(Own emphasis).
(2) Where a supplier has accounted for an incorrect amount of output tax as contemplated
in subsection (1 ), that supplier shall make an adjustment in calculating the tax payable
by that supplier in the return for the tax period during which it has become apparent that
the output tax is incorrect, and if -
(a)
(b) the output tax actually accounted-for exceeds the output tax properly chargeable
in relation to that supply, that supplier shall either make a deduction in terms of
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section 16(3) in respect of the amount of that excess (such amount being deemed
for the purposes of that section to be input tax), or reduce this amount of output
tax attributable to the said tax period in terms of section 16(4) by the amount of
that excess. Provided that the said deduction shall not be made where the excess
tax has been borne by a recipient of goods or services supplied by the supplier
and the recipient is not a vendor, unless the amount of excess tax has been repaid
by the supplier to the recipient, whether in cash or by way of a credit against any
amount owing to the supplier by the recipient ."
5. 2 FirstRand contends that there was a reduction of the agreed monthly service fee and
FirstRand was therefore entitled to claim input VAT in respect of the VAT component
of that reduction . SARS, on the other hand, contends that it was not a reduction of the
monthly account fee, but rather a payment to incentivise FirstRand 's clients" .
[6] The joint practice note referred to supra was supplemented by an additional joint practice
note which served to supplement the common cause facts. On an analysis of the relevant
common cause facts (which will be referred to infra) the dispute as formulated in paragraph
5.2 of the joint practice note (as quoted supra) essentially relates to the issue whether VAT
on service fees which the Taxpayer debited against the accounts of its clients in terms of a
banker/client agreement , could be deducted as an input tax in subsequent VAT returns after
the service fees were subsequently credited to the accounts of the clients.
[7] In the SARS Rule 31 Statement of Grounds of Assessment and Opposing the Appeal, the
grounds upon which SARS rely for its disallowance of the deduction are stated as follows
under the item "Issues in dispute " namely:
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"5. The issues in dispute relate to the 2020/08- 2021107 VAT periods, more specifically the VAT
treatment of the monthly cashback rewards provided by FirstRand to clients of its rewards
programme if certain qualifying criteria are met.
6. In casu the specific operation of this rewards incentive operated by FirstRand, entailed FNB
crediting qualifying FNB account holders accounts with a percentage of their monthly account
fee normally charged at month end.
7. FirstRand contends that it is entitled to input tax deductions in respect of these fee reduction
amounts (cashback repaid/rewards) made to clients. These input tax claims are predicated on
the basis that FirstRand is liable to pay output tax on the total amount of account fees invoiced,
which was subsequently reduced. Consequently, pursuant to section 21(1)(c) of the VAT Act,
the monthly account fees in respect of which output tax were paid, should be adjusted
according to the reduced amounts.
8. SARS on the other hand, contends that the cashback rewards made to clients of FirstRand
does not constitute a reduction/alteration of a previously agreed consideration with clients as
contemplated in section 21(1)(c) of the VAT Act. In addition, none of the clients paid any
consideration for the 're-paid ' granted.
9. In short, the crediting of the accounts does not constitute a credit note event."
[8] In essence therefore. the dispute relates to whether the crediting of service fees previously
debited by the Taxpayer against its clients' accounts in terms of the cashback/rewards
scheme triggers the provisions of section 21(1)(c) of the VAT Act.
THE COMMON CAUSE FACTS:
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[9] The relevant facts which inform the dispute are common cause. The parties' joint practice
note recorded the common cause facts as follows:
"Common cause facts relevant to the relief sought:
7. 1 The assessments relate to the tax periods August 2020 to July 2021 ('the disputed tax
period').
7.2 The amount disallowed by SARS as input tax is R5 551 275.52".
7.3 FirstRand did make the supply of either goods and/or services to its clients. In return,
consideration was received by FirstRand from its clients. The consideration so received
assumed the form of a monthly account fee (banking fee) paid. FirstRand also accounted
for output tax in relation to the total account fees involved and received from its clients.
7. 4 FirstRand provided cash back rewards to clients of its reward programme if certain qualifying
criteria were met.
7. 5 The monthly cash back rewards provided by FirstRand entailed that FirstRand credited
qualifying FirstRand account holders' accounts with a percentage of their account fee
normally charged at month-end, ff certain qualifying criteria are met.
7.6 The monthly account fee for operating and maintaining the FNB Fusion Account, at an
agreed monthly fee, constitutes a taxable supply in terms of the VAT Act. The taxpayer
levies VAT on this service.
7. 7 FirstRand accounts for VAT on supplies made and First Rand includes a VAT charge on
the monthly accounts of clients.
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7. 8 The monthly bank statement send by FirstRand to a client is compliant with section 20 of
the VAT Act and constitutes a tax invoice, as contemplated in section 20 of the VAT Act.
7.9 FirstRand furnished VAT returns wherein ;t accounted for output VAT.
7. 1 0 FirstRand provided a tax invoice in relation to the initial monthly account fee that was levied.
7. 11 FirstRand claimed an input tax credit to the value of RS 551 275. 52. The quantity of the
amount is not disputed by the respondent".
(1 O] In the parties' additiona l joint practice note the parties recorded the following additional facts
to be common cause:
"1. The respondent admits that the vendor (FirstRand) made supplies of services to its clients for
consideration and that some of the agreements pertaining thereto may have been conveyed
by way of data message.
2. The Terms and Conditions of the contract between the taxpayer and its clients are provided by
the taxpayer and accepted by its clients on the following sales channels:
2. 1 Sales call centre;
2. 2 By the branch;
2. 3 Via on line banking;
2.4 Via te banking 'App'.
3. The respondent accepts that the terms of conditions of agreements entered into with clients
are I were at some stage displayed on ;ts (FirstRand) website.
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4. One of the terms of the contract between the taxpayer and its clients is that the taxpayer
charges its clients a monthly account fee, which is contained in the pricing guide. Reference is
made to the pricing guide in the Terms and Conditions of the contract. The pricing guide
therefore forms part of the contract between the taxpayer and its clients.
5. The Pricing Guide further states that FirstRand reserves the right to change fees. If there is a
change in fees, the client is given 20 business days' notice by way of a method as described
and required by The Banking Association of South Africa's Code of Banking Practice, which
includes:
5. 1 letter, statement messages or other personal notices;
5. 2 notices or leaflets in branches or outlets;
5. 3 A TM or electronic banking system messages;
5.4 telephonic announcements, e-mail or short message service (SMSJ;
5. 5 announcement on our website or any other electronic media;
5. 6 media advertisements; or
5. 7 any other communication channel available to us.
6. It is common cause that the monthly account fee for operating and maintaining the FNB Fusion
Gold account, at an agreed monthly fee, constitutes a taxable supply in terms of the VAT Act.
The taxpayer levies VAT on this service.
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7. During the relevant period, the taxpayer afforded its client the opportunity to reduce the monthly
account fee if they met certain criteria. This was communicated to the taxpayer's clients in
several ways, including:
7. 1 By a call centre;
7. 2 By a branch, if visited by a client;
7.3 By the taxpayer's Banking 'App';
7. 4 On the taxpayer's webs;te;
7. 5 0 the taxpayer's Pricing Guide;
7.6 On the eBucks webs;te;
7. 7 On the eBucks eam rules.
8. The examples of how the reduction (rebate) was communicated to the taxpayer's clients, was
as follows:
'Earn up to 100% of your monthly account fee in cash back when you have an FNB Fusion Gold
account and your personal loans are with FNB; and
If you are an FNB customer on the Spousal Pricing Option and you meet the above qualifying
criteria you will get 100% of your monthly fee back (R59) in cashback.
The monthly account fee cashback will occur as long as the qualifying criteria is met and this
will be a rebate on your FNB Fusion Gold account over the duration of the loan term' (own
emphasis)'.
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9. If a client of the taxpayer qualifies for the cash back of its monthly account fee, the payment is
reflected as a credit on the client's bank statement, which is referred to and discovered and
shows a credit amount labelled 'Monthly fee rebate'.
10. It is admitted that data messages were exchanged between clients and the bank.
11. The monthly account fee is reflected on the bank statement which reflects the account detail
and fees chargeable.
12. It is admitted that the vendor 'charged & received' fees from clients.
13. Subsequent to the conclusion of the agreement between FirstRand and its clients, FirstRand
informed its clients that they could obtain cashbacks, if they complied with certain
requirements.
14. It is admitted that the vendor (FirstRand) may have sent a variety of data messages conveying
various messages to clients.
15. It is admitted that rewards were provided to qualifying clients.
16. FirstRand credited qualifying FirstRand account holders' accounts, on the 81h day (or as close
thereto) of the following month after having met the qualifying criteria, with an amount.
17. It is admitted that the vendor claimed an input tax credit to the value of R5 551 27552. The
respondent does not dispute the quantum of the amounf' .
[11] The Taxpayer called only one witness , Mr Jagjivan, who is the Head of Pricing and Rewards
of Private Segments at the Taxpayer . He testified that the cashback scheme was introduced
as a strategy devised by the Taxpayer to increase/protect the market share of the Taxpayer
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who was competing against another commercial banking services/credit provider who was
offering very competitive banking service fees to clients. The Taxpayer therefore initiated a
scheme marketed as a "cashback" scheme which resulted in that the agreed service fees
being debited monthly on a client's transactional account being reversed and credited to the
client's transactional account later in the month on condition that the client complied with
certain criteria. The criteria essentially required that the client had to make use of credit
facilities offered by the Taxpayer through one of its divisions such as a personal loan and/or
motor vehicle finance and further had to keep his/her account in good standing.
(12) The witness further testified that a so-called "eBucks scheme" (which is a points-based
rewards incentive that clients could utilise at partners of the Taxpayer to obtain rebates on
the purchase of specific products) was used as a practical means to determine whether the
account of the specific client was in good standing. For that reason, all the clients eligible
for a cashback reward had to qualify for the eBucks scheme.
[13) In summary, having regard to the common cause facts as recorded in the respective practice
notes and the evidence of the witness called on behalf of the Taxpayer , the following very
concise summary of the material facts are to be noted:
[13.1] An agreement was entered into between the Taxpayer and clients in terms whereof
the Taxpayer provided a range of banking services to its clients and for which
services the Taxpayer debited a monthly service fee from the client's transactional
account , which is subject to VAT;
(13.2] The Taxpayer introduced a scheme ("the cashback scheme') in terms whereof the
monthly agreed service fee which was debited against the transactional account
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of a client in a specific month was repaid to the client by way of a credit on the
client's transactional account, after it was established that the client has complied
with qualifying criteria; The purpose thereof was to reduce or repay the agreed
service fee payable on the transactional account;
[13.3] The cashback scheme was marketed as a means for clients to reduce in toto or in
part (depending on the nature of the account) the agreed banking service fee.
[13.4] The underlying motive for the Taxpayer introducing the scheme was to
protect/advance its share in the credit product supply market.
[13.5] The role of the eBucks incentive in the cashback scheme was solely to be used as
a yardstick to determine if the accounts of a participating client were in good
standing.
THE MERITS OF SARS' GROUNDS FOR DISALLOWING THE DEDUCTION :
[14] On a perusal of the document UFinalisation of audit " addressed by SARS to the Taxpayer,
dated 4 October 2022, it appears that SARS was under the incorrect factual impression that
the eBucks incentice provided by the Taxpayer to its clients provided a means whereby the
reduced service fee formed part of, or were converted into the eBucks benefits which a client
received. However, the SARS Rule 31 notice as quoted in paragraph [7J supra does not
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refer or rely on the eBucks scheme but concludes to state that the crediting of the accounts
does not constitute a credit note event. 1
[15] During the hearing of the appeal SARS raised an argument which was not raised in the Rule
31 statement or in the joint practice notes. Counsel acting on behalf of SARS insisted that
this argument is an argument in support of the SARS statement that the crediting of the
accounts does not constitute credit note events, and further conceded that the eBucks issue
may have been incorrectly interpreted and applied by SARS during the audit preceding the
decision . A concise summary of the SARS' argument as advanced during the hearing of the
appeal is set out hereunder.
[16] With reference to the definition of "supply", "services" and "consideration " as defined in the
VAT Act, it was argued on behalf of SARS that, in essence , there were two transactions .
The first transaction consisted of a transactional banking service provided by the Taxpayer ,
and there is a direct link between the supply of the banking services and the considerat ion
payable by the client being the agreed service fee. The second, and distinctly different
transaction (so it was argued) , consisted of actions performed by the client (which was also
referred to as behaviour compliance/modification) in terms whereof the client is called upon
to join the eBucks programme , must have an active personal loan with the Taxpayer subject
to certain conditions , operate an active FNB Fusion Transactional Account , and ensure that
all the accounts are in good standing with the Bank. It was argued that the bank charges are
not made in respect of those services and that the Taxpayer and the client instead agreed
that, if those behavioural actions have been met (in terms of transaction 2) the Taxpayer will
1 Vide: Paragraph 9 of SARS' rule 31 st atement as quoted in paragraph (7} supra.
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make the payment of an amount which is credited to the client's transactional account. In
conclusion it was argued that:
"This cashback is thus not a discount as it does not reduce the price of the banking service; it is
consideration paid for a separate supply made by the client, with the original supply and its VAT
treatment remaining entirely unchanged".
[17] Concisely stated, it was submitted on behalf of SARS that the credit of the service fee into
the client's account served as a payment for a service which the client rendered, such
service consisting therein that the client was compliant with the criteria referred to in
paragraph [16] supra.
(18] In my view the argument raised on behalf of SARS cannot be upheld. On a perusal of section
21(1)(c) of the VAT Act, it is clear that the VAT Act does not require any specific motive or
stated reason for reducing the previously agreed consideration. It thus follows that a
reduction in the original agreed consideration does not require an alteration of the original
agreed service as a sine qua non. The fact that the original supply remains the same, as
submitted by SARS and quoted in paragraph [16) supra, is thus irrelevant.
(19) The requirement to trigger section 21(1)(c) of the VAT Act is that the previously agreed
consideration for a supply (of goods or services) must be altered by agreement with the
recipient, either due to the offer of a discount or for any other reason. Should this
jurisdictional requirement be satisfied, the Taxpayer is entitled to an adjustment in terms of
section 21 (2) of the VAT Act on condition that the administrative requirements of subsection
(i) and (ii) of section 21(1)(c) are met. The inquiry into the jurisdictional requirements is a
factual enquiry which requires the Taxpayer to establish the facts on a balance of
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probability.2 It is clear that section 21 (1)(c) of the VAT Act does not refer to any time period
between the previously agreed consideration and the alteration which means that the supply
at an agreed consideration and the alteration event may be separated in time and place.
Whether it is an alteration event (or credit note event) or not, is a factual issue established
by admissible evidence on a balance of probability by the taxpayer.
[20) In casu the Taxpayer established through common cause facts and unchallenged evidence
that the Taxpayer entered into a service agreement with clients which entitled the Taxpayer
to charge a consideration (bank fee) for providing banking services. The Taxpayer further
established as a fact that existing and prospective clients were invited in the media, through
advertising as well as electronic communication, that a reduction of bank fees are available
to clients who comply with certain criteria and conditions. In the event of clients meeting the
said criteria and complying with these conditions, the bank fees (consideration) were
reduced. This was called a "cashback reward" and consisted therein that the respective
client's account was again credited with the banking fee. In my view the evidence clearly
established that it was the bank fee (previously agreed consideration) which was credited to
the transactional account of the client in order to achieve the effect that the client's banking
fees were either reduced or waived in toto. This transaction thus altered the previously
agreed consideration in terms of an agreement between the Taxpayer and the client.
[21) Counsel acting on behalf of the Taxpayer referred to decisions of the Supreme Court of
Appeal in relation to the requirement of a factual link between expenses incurred and
supplies made in the context of VAT.3 In all these matters, although they did not relate to
2 The Tax Administration Act, 28 of, section 102(f).
3 Consol Glass v SARS 83 SA TC 186 (SCA).
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section 21 of the VAT Act, the factual link between expenses incurred and supplies made
was regarded as a requirement for purposes of those disputes. In the De Beers matter and
the Woolworths Holdings Ltd matter, the court investigated the nature of the enterprise
involved in determining the issue of a factual link. In my view it is not necessary for purposes
of section 21(1)(c) of the VAT Act to investigate the nature of the enterprise in order to
establish whether there was a reduction of consideration by way of a discount or for any
other reason. All that is required is evidence of a reduction of a previously agreed
consideration because the reference to "for any other reason" is so wide as to enable an
enterprise to reduce a consideration for reasons which are not relevant in the context of the
nature of its operations.
[22] In my view the argument advanced on behalf of SARS as summarised in paragraphs [16]
and [17] supra is an argument based on a conflated interpretation of various unrelated
sections of the VAT Act. Section 21(1)(c) is not complicated and requires a factual enquiry.
The attempt to introduce an argument that there are two distinctly different transactions and
that the second transaction elevates the client to the position of a virtual supplier of services
or goods to the Taxpayer for which the client is paid, completely ignores the established
principle that the evidence should be considered as a whole, and that certain facts in
isolation should not be elevated while other facts are simply ignored. In casu, the facts that
establish a causal link between the original agreed consideration and the subsequent
alteration thereof in terms of an agreement were established by agreement in the joint
practice notes and unchallenged evidence of Mr Jagjivan.
SARS v De Beers Consolidated Mines 2012 (5) SA 344 (SCA).
SARS v Woolworths Holdings Ltd {2025] ZASCA 99 (4 July 2025).
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CONCLUSION:
[23] Considering the common cause facts and uncontested evidence, the Tax payer established
the following:
[23.1] An agreement between the Taxpayer and its customers which provided for a
monthly account fee on the transactional account, which was debited from the
customers' accounts from month to month in terms of that contract;
(23.2] The Taxpayer accounted for output VAT and furnished a return in relation to the
relevant tax period;
[23.3] The Taxpayer provided its customers with a tax invoice in respect of the monthly
account fee and submitted a VAT return reflecting the fees that were charged;
(23.4] The Taxpayer reduced the initially agreed monthly account fee by agreement with
customers, if the customers met the qualifying criteria by way of a "cashback "
consisting of the previously agreed service fee amount ( or part thereof) being credit
to the customer's account, which included VAT;
(23.5] The Taxpayer provided the customers with a credit note, consisting of the bank
statement on which the rebate (or discount) was reflected.
(24] The jurisdictional and administrative requirements of section 21(1)(c) and section 21(2)(b)
of the VAT Act have been complied with, as a result of which the Taxpayer's appeal should
be upheld.
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[25] This finding implies that the alternative relief claimed by Appellant in the Rule 32 Statement
becomes moot.
COSTS:
[26] The grounds upon which an order for costs may be made by this court in favour of the
Tax payer are restricted4 . It was argued on behalf of the Taxpayer that the decision of SARS
was unreasonable as a result of which an order for costs should be made in favour of the
Taxpayer , to be taxed on Scale C.
[27] In support of the prayer for such costs, counsel acting on behalf of the Taxpayer argued that
the conduct of SARS was unreasonable in the sense that the initial grounds for disallowing
the input VAT was based on a misunderstanding of the facts and the implications of the
eBucks rewards system on the "cashback scheme" which was clarified by the Taxpayer
during the audit and in the Rule 32 notice, thereafter in heads of argument and also during
the trial. It was further argued that SARS should have realised that there was no basis to
persist in its decision but instead evolved the grounds of dispute into new grounds which
were not initially raised.
[28] On behalf of SARS it was argued that SARS is entitled to test the boundaries of legal
interpretation and to proceed matters to court in order to obtain clarity on issues which may
be contentious for purposes of future effective tax collection. Essentially, it was argued on
behalf of SARS that it was necessary to proceed with the matter to the Tax Court in order to
4 Tax Administration Act, section 130.
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obtain clarity on the implications of section 21 (1)(c) of the VAT Act in circumstances where
incentive schemes are the proverbial order of the day.
(29) Mitigating against awarding costs to the Taxpayer, I have to consider the fact that the primary
function of SARS is to proverbially fill the fiscus, while this court's function is to protect the
fiscus. In other words, I am of the view that the test for unreasonableness as it appears in
section 130 of the Tax Administration Act sets a high bar and it should only be applied in
matters where there are, without any doubt, such a degree of unreasonableness that it
seriously offends the sense of justice of a reasonable man.
[30] In casu I am of the view that I cannot make such a finding
In the result, the following order is made after consulting the members of this court:
[1] The appeal is upheld.
[2] SARS is ordered to alter the additional assessment to allow for the deduction of
RS 551 275.52 for the tax period August 2020 to July 2021.
APPEARANCES
FOR THE APPELLANT :
INSTRUCTED BY:
PA VAN NIEKERK
JUDGE OF THE GAUTENG DIVISION,
PRETORIA
ADV. C LOUW SC
Weber Wentzel Attorneys