Tax Opinions
Certainty before you sign, not after.
A written opinion sets out the tax consequences of a transaction before you commit — and creates a defensible record if SARS ever revisits it.
What you receive
An opinion you can act on and rely on
Reasoned and referenced
Every conclusion is tied to the legislation, case law, and SARS interpretation notes it rests on — not just a bottom line.
Penalty protection
A timely opinion from a registered practitioner can support a 'no understatement penalty' position where SARS later disagrees.
Transaction-specific
Restructures, share sales, loan accounts, trusts, property disposals, and cross-border payments — each analysed on its own facts.
Board-ready format
Written so directors, funders and auditors can rely on it, with facts, assumptions and scope clearly stated.
Typical questions
Matters clients ask us to opine on
- Is this restructure a taxable disposal, or does a corporate roll-over relief provision apply?
- How should a director's loan account be treated for deemed dividend and fringe benefit purposes?
- Are payments to a non-resident supplier subject to withholding tax, and does a treaty reduce the rate?
- Does this arrangement fall foul of the general anti-avoidance rules, and is it reportable?
Need an opinion on a transaction?
Share the facts and the timeline. We will scope the opinion and quote before any work begins.
