Are You Prepared for an Unexpected Tax Audit in South Africa? How Tax Risk Insurance Can Safeguard Your Business

In today’s complex tax environment, businesses and individuals in South Africa face increasing scrutiny from the South African Revenue Service (SARS). The rise in transfer pricing audits, general anti-avoidance measures (GAAR) reviews, and tax disputes has led to significant financial strain, even for those who diligently comply with tax regulations.

The question is:

💡 When the Tax Authorities Come Knocking, Will You Be Ready? 💡

Many businesses underestimate their tax risk exposure—until it’s too late. Even if you have an impeccable tax record and a trusted accountant, SARS audits are becoming more aggressive, and disputes can lead to substantial costs.

As a part of the Tax Risk Underwriters advisory committee, I’ve seen firsthand how structured tax risk cover can protect businesses and individuals from unforeseen financial burdens related to tax audits and disputes. Tax Risk Insurance is a crucial tool for ensuring financial security and peace of mind.

Understanding Tax Risk Insurance

Tax Risk Insurance provides coverage for the costs associated with defending against SARS tax audits and disputes. If selected for an audit or if there’s a dispute over a tax assessment, the insurance appoints and pays for a team of highly qualified tax professionals—including accountants, tax attorneys, auditors, and tax specialists—to manage the matter on your behalf, ensuring a fair outcome.

Why You Need Tax Risk Insurance

  1. Increased Audit Activity – SARS is conducting more transfer pricing audits, GAAR reviews, and aggressive assessments than ever before. The likelihood of an audit or dispute is higher than most businesses anticipate.
  2. Unpredictable Selection – Even if you are fully compliant, SARS can select your business or personal finances for an audit at any time.
  3. High Defense Costs – The cost of defending a tax audit or dispute can be substantial, potentially impacting your financial stability.
  4. Complex ProceduresTax audits and disputes are intricate and stressful, requiring expert handling to navigate effectively.

The Benefits of Tax Risk Insurance

Financial Protection – Covers the legal and professional costs of defending against SARS tax audits and disputes.

Access to Expertise – Provides top-tier tax specialists to handle audits and disputes on your behalf.

Peace of Mind – Allows you to focus on business growth and operations without worrying about unexpected tax liabilities.

Who Should Consider Tax Risk Insurance?

  • High-Net-Worth Individuals – More likely to be targeted by SARS audits.
  • Small to Medium-Sized Enterprises (SMEs) – Often lack in-house tax expertise and face significant financial exposure.
  • Multinational Enterprises (MNEs) – Subject to complex transfer pricing audits and compliance requirements.
  • Trusts – Frequently scrutinized by SARS due to perceived tax avoidance risks.

Join Our Upcoming Webinar Series

Hosted by GreatSoft and sponsored by Tax Risk Underwriting Managers

GreatSoft is delighted to invite you to our inaugural series of three educational webinars, designed to provide valuable insights into critical tax and accounting topics. This free CPD-accredited series is proudly sponsored by Tax Risk Underwriting Managers, leaders in tax risk insurance.

Each session will feature industry experts, offering practical guidance and valuable discussions tailored to GreatSoft clients.

Event 1 – Dispute Resolution: Rights and Remedies Available to Tax Practitioners and Their Clients

📅 Date: 12 February 2025
Time: 10:00 AM – 11:30 AM (GMT+2)
🔗 Register here

A tax audit isn’t a matter of IF, but WHEN. Make sure your business is protected.

Please look out for EVENT 2 & 3 as follows:


Event 2 – Trusts and IT3(t): Critical Aspects of Trust Administration

Date: Monday, 24 March 2025 (tentative)
Time: 10:00 AM – 11:30 AM
Topic: Trusts and IT3(t): Critical Aspects of Trust Administration


Event 3 – Trusts and IT3(t): Critical Aspects of Trust Administration

Date: Monday, 14 April 2025 (tentative)
Time: 10:00 AM – 11:30 AM
Topic: Introduction to Tax Litigation Techniques: A Practical Guide for Tax Practitioners


Not South African? – I have you “covered!”

With revenue services all over the globe heightening tax scrutiny, multinational enterprises, international investors, and global tax professionals face increasing challenges from aggressive tax authorities worldwide. Whether dealing with transfer pricing disputes, permanent establishment (PE) controversies, controlled foreign corporation (CFC) rules, or state aid investigations, international entities require expert guidance to navigate complex tax landscapes.

With over three decades of experience in international tax and transfer pricing litigation, I specialize in defending businesses against aggressive tax audits, structuring compliant global tax strategies, and mitigating financial exposure to tax risk. I advise clients across the U.S., EU, UK, Africa, Asia, and Latin America on disputes involving respective tax authorities.

I provide strategic tax risk management solutions, helping businesses proactively structure transactions to align with OECD and UN Model Conventions, BEPS Action Plans, and local anti-avoidance laws. My work in high-profile tax trials, state aid disputes, and transfer pricing litigation positions me as a valuable consultant for law firms, tax professionals, and multinational corporations seeking expert witness testimony, dispute resolution strategies, and defense in international tax courts.

Suppose your business operates in multiple jurisdictions and faces tax risk from aggressive assessments, transfer pricing audits, or anti-avoidance rules. In that case, I offer tailored solutions to ensure regulatory compliance, tax efficiency, and protection against unexpected liabilities.

Proactive Tax Risk Management: Establishing Tax Steering Committees

I firmly believe that tax risk management should begin long before any interaction with tax authorities. Instead of reacting to audits or disputes, multinational enterprises (MNEs) must adopt a proactive, structured approach to managing tax risk across their entire organization. That’s why I advocate for the establishment of Tax Steering Committees—dedicated teams that oversee tax governance, compliance, and strategy at the highest level. These committees ensure that tax risk is not siloed within the finance or tax departments but is integrated into broader business decision-making. By implementing robust documentation, transfer pricing policies, and risk assessment frameworks, businesses can minimize exposure to aggressive tax audits, disputes, and reputational damage. Through my work with MNEs, I help design and implement effective tax risk management structures, ensuring that companies are always one step ahead of revenue authorities rather than scrambling to defend their position after an audit has begun.

To assist you, I am making the following publications available to you FREE:

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France vs SAS Roger Vivier: TRANSFER PRICING CASE

The judgment revolves around a tax dispute between SAS Roger Vivier Paris, a distributor of luxury goods, and the French tax authorities. The core issue concerns transfer pricing adjustments made for the financial years 2012–2014, with the tax authorities asserting that SAS Roger Vivier Paris indirectly transferred profits to foreign-related parties in non-arm’s length conditions.