Taxing Times Survey 2025

PwC’s Taxing Times 2025 Survey reveals shifting dynamics in South Africa’s tax landscape 

Johannesburg, 13 November 2025 – South Africa’s corporate tax environment is undergoing a significant transformation. As the South African Revenue Service (SARS) accelerates its modernisation agenda and sharpens its enforcement posture, businesses are experiencing a dual reality: improved efficiency through digital platforms but also increased complexity and scrutiny in their interactions with the tax authority. In this context, SARS has welcomed the Medium-Term Budget Policy Statement (MTBPS) tabled in Parliament on 12 November 2025 by the Minister of Finance, Enoch Godongwana, which revises the 2025 Budget net tax-revenue estimate from R1 985.6 billion to R2 005.3 billion, underscoring the government’s commitment to fiscal resilience and enhanced revenue collection. 

Drawing on insights from 200 corporate taxpayers across 18 industries, PwC’s Taxing Times 2025 report captures the evolving relationship between SARS and the business community—highlighting both progress and persistent pressure points. 

A system in motion, but not without friction 

While SARS has made strides in streamlining processes and embracing digital tools, many taxpayers still report challenges in navigating audits, verifications and dispute resolution. The report paints a picture of a tax authority that is evolving rapidly, but where consistency and communication remain areas of concern. 

The numbers behind the narrative 

• Audit and verification timelines are improving: 31% of respondents indicated that their audits were finalised within 1-3 months up from 28% in 2024. 
• Transfer pricing continues to pose challenges, with 74% of audits taking more than a year to conclude. Additionally, the use of the Mutual Agreement Procedure (MAP) and the number of dispute settlements are both increasing. 
• Understatement penalties (USP): 59% of participants who viewed SARS as aggressive in applying USP said SARS cited section 223 of the TAA, but its approach felt overly forceful. 
• VAT refund processing (within 21 days) has improved, but verification delays continue to impact cash flow. 
• Alternative Dispute Resolution (ADR) is widely used and effective, with 76% of participants reporting benefits such as reduced penalties and interest. 
• Suspension of Payment Requests (SOP) are being addressed and approved, says 40% of the participants.
• Voluntary Disclosure Programme (VDP) rejections are increasingly due to refund positions and recent defaults, reflecting a shift in SARS’ approach. 

Technology’s promise, but adoption lags 

SARS’ investment in automation and AI is beginning to reshape taxpayer interactions. However, adoption on the AI chatbox remains low—only 5% of respondents have used the feature, though 70% of those who did find it helpful. E-invoicing (VAT) is still in development and is expected to significantly improve verification and refund turnaround times once implemented. 

Trust, transparency and the human element 

Despite digital progress, many taxpayers continue to report inconsistent audit practices, vague communication and limited procedural transparency. Trust in SARS remains unchanged for most respondents, with mixed feedback on service delivery and the effectiveness of relationship managers. 

Pillar II: global tax reform reaches South Africa  

The survey also captures taxpayer sentiment around the OECD’s Pillar II initiative, which introduces a 15% global minimum tax rate for large multinational enterprises that meet a certain threshold (for MNE’s with consolidate annual revenues of € 750million or more). While 38% of survey participants understood the aim of Pillar II, nearly half expressed little concern about its impact—suggesting early alignment. A quarter of respondents indicated that they had appointed advisors to assist with compliance, reflecting a proactive approach to navigating this international tax reform. 

Voluntary Disclosure Programme (VDP): A shifting threshold for relief  

The VDP remains a valuable tool for regularising tax affairs, but the criteria for acceptance are evolving. This year, the most common reason for rejection were being in a refund position or having a similar default within the past five years—making a departure from previous years where voluntariness and completeness were the primary barriers. A substantial proportion of participants (79%) who utilised the VDP indicated that it facilitated their company’s proper declaration of defaults, enabling them to correct assessments and avoid penalties for understatement. These trends highlight the importance of understanding SARS’ current expectations and preparing robust applications to avoid delays or denials. 

A call for balanced reform