Tax Controversy

SA taxpayers note an improvement in tax audit process but more remains to be done around service delivery – PwC tax survey

South Africa’s tax administration system has undergone significant change in the past two years with a number of leadership, structural and policy changes. More recently, the Government introduced several economic measures, including tax measures in order to protect businesses and vulnerable employees during the COVID-19 lockdown period and after it has been lifted.

Added to this, companies are seeing an increase in tax audits and disputes, and all signs point to even more intense focus by the tax authorities in the future. While companies are facing many challenges, it is also positive that there are improvements in the efficiency of the tax administration process, especially the time taken by the tax authorities to verify tax audits and issue payment of VAT refunds.

PwC’s Annual Taxing Times 2020 Tax Controversy and Dispute Resolution Survey was created to benchmark taxpayers’ experiences when dealing with the South African Revenue Service (SARS). The latest survey, the third in the annual series, was conducted between May and July 2020. A total of 107 corporate respondents completed the survey. Taxpayers from across 23 industries participated in the survey.

Elle-Sarah Rosatto, PwC Lead for Tax Controversy & Dispute Resolution says:

“The survey aims to gauge corporate taxpayers perceptions when dealing with SARS and to use their feedback to support constructive engagement with SARS about how it can improve public trust, efficiency and confidence in the tax administration system as well as to improve its stakeholder engagement.”

The report presents respondents feedback concerning the Voluntary Disclosure Programme (VDP), issues faced by corporates in managing audits and disputes, SARS’ service delivery, and the impact of the COVID-19 measures on their tax affairs.

Key findings from the survey include:

The audit process: 48% of survey respondents felt that they are ‘extremely likely’ to be selected for an audit/verification by SARS following submission of their Corporate Income Tax (CIT) returns. 66% of survey respondents stated that SARS had granted their extensions to submit and gather information ‘most of the time’ or ‘always’. It is notable that there has been a steady improvement in the length of time taken to finalise a verification audit with 49% of respondents (compared to 40% in 2018) indicating that it takes three months to complete an audit (as promised in the SARS Service Charter).

Voluntary Disclosure Programme (VDP): The VDP gives taxpayers an opportunity to correct defaults previously submitted to SARS without incurring potentially significant penalties. This year, just under half of respondents (46%) said they had made use of the VDP application process. It is concerning to note that only 20% of respondents that had made use of the VDP had their applications approved within three months, while 37% reported that their applications took more than 12 months to finalise. More than half of respondents (54%) do not believe that the VDP has assisted their company to obtain the required relief. Furthermore, many respondents stated that they find the application process confusing, with 73% of participants indicating that an interpretation note would be useful when considering or drafting an application process.

SARS’ delivery process: Less than half of respondents (47%) believe that the SARS Service Charter makes ‘no’ difference to the quality of SARS’s delivery service, down from 62% in 2019. Most participants (98%) believe that SARS’ official key performance indicators should be linked to the SARS Service Charter in order to incentivise improved performance by SARS officials (up from 54% in 2019).

COVID-19 measures: Only a quarter of respondents believe that SARS and National Treasury have provided adequate relief measures during and after the lockdown period, while 30% say that more should have been done to relieve liquidity and promote business continuity. Just over half of respondents (54%) said they took no action to reduce or discontinue any of their tax obligations, while 34% took advantage of payment relief for PAYE. A further 20% reduced or discontinued provisional tax payments, while a minority made use of relief offered for VAT, Corporate Income Tax (CIT) annual payments, and customs and levies.

SARS’ delivery process during the COVID-19 pandemic: When asked whether SARS was equipped to handle their companies queries service-related issues during or after the lockdown period, only 3% of respondents said that SARS was ‘always’ prepared. A further 23% believed SARS was ‘never’ equipped to help them.

Rossato adds: “This is concerning and suggests that SARS urgently upskills its officials to ensure that they are up to date and able to action requests in line with the COVID-19 related tax measures.”

Taxpayer behaviour

Lullu Krugel, Chief Economist for PwC Africa says:

“A better understanding of the behaviour of taxpayers and their attitudes towards taxation can improve both voluntary compliance and the efficiency of tax administration.”

Evidence suggests that four factors drive tax compliance: deterrence, social norms, fairness and trust, and the complexity of the tax system. Our survey summarises the responses of corporate taxpayers to questions about these drivers.

It is interesting to note that fewer respondents (55%) believe that there will be a ‘good chance’ that their company will be audited by SARS, compared to 60% in 2018.

How taxpayers are treated and how they perceive tax rates can be highly influential. This year, 81% of respondents consider corporate tax rates to be acceptable or fair (2019: 78%; 2018: 69%).

Taxpayers’ confidence in the government is important as it gains support for compliance, and for minimising avoidance of rules and regulations. While trust takes time to be earned, it can also quite easily be lost. Half of survey respondents stated that they still have confidence in the government, while the other half said they had lost confidence. Only 1% said they have a lot of confidence in the government.

It is also notable that three-quarters of respondents indicated that it takes them more time to figure out tax administration and SARS processes.

The way forward

Survey participants were asked what they thought SARS should do to improve its service to taxpayers. More than half (55%) favoured actions to improve the technical skills of SARS officials and improve facilities to communicate with SARS directly (51%), excluding the call centre and eFiling. 23% of respondents also requested an improvement in turnaround times, and 32% were in favour of improving SARS’ enforcement capabilities to broaden the tax base.



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Sanchia  Temkin

Sanchia Temkin

Senior Manager, Media Relations, PwC South Africa

Tel: +27 (0) 11 797 4470

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