Abstract:
This dissertation analyses the effect that the tax time periods together with the
“pay now, argue later” rule has on the taxpayer. In looking at the tax time
periods in terms of the Tax Administration Act, I examine whether the tax time
periods favour SARS, and if so what affect that has on the taxpayer. In
addition, I look at what effect the “pay now, argue later” rule has on the
taxpayer. The effect of the rule is found in the various enforcement
mechanisms at SARS’ disposal and what their physical impact is on the
taxpayer. Therefore, I discuss the various enforcement mechanisms as
provided for in the Tax Administration Act as the ‘effect’ that the “pay now,
argue later” rule has on taxpayers. I also make submissions about what
effects the enforcement mechanisms themselves have on taxpayer. My
dissertation concludes that the tax time periods do favour SARS and what the
effect thereof together with the ”pay now, argue later” rule is the taxpayer. I
make the submission that this results in the ‘scale’ being tipped in favour of
SARS. In concluding, I make a suggestion as to what needs to be done in
order to bring a balance in the relationship between SARS and taxpayers.
