Is Your Historic Tax Position Defensible? Why the New SARS VDP Guide Matters More Than Ever
Published: 19 June 2026
Author: Tender Da Gama
Reading Time: 3 minutes
The South African Revenue Service (SARS) recently released the updated Guide to the Voluntary Disclosure Programme (Issue 2), providing further clarity on how SARS evaluates voluntary disclosures and approaches historical tax non-compliance.
For businesses with unresolved tax matters, the updated guidance reinforces an important reality: a Voluntary Disclosure Programme (VDP) application is not simply an administrative process. It requires careful planning, technical analysis and a clear understanding of the legislative framework governing tax compliance.
Historic Tax Exposure Often Extends Beyond VAT
While VAT is frequently the first area businesses review, historical non-compliance can arise across multiple tax types, including:
In many cases, the issue is not deliberate non-compliance. Historical tax exposure often develops due to incorrect tax treatment, process failures, resource constraints, legislative changes or assumptions that were never revisited.
The challenge is that unresolved matters rarely disappear. They often surface during:
By this stage, the financial and operational consequences can be significant.
Key Considerations Under the Updated VDP Framework
The revised SARS guidance highlights several areas businesses should carefully assess before pursuing a VDP application.
Understand the Nature of the Default
Businesses must clearly identify the historical non-compliance and understand the circumstances that gave rise to the default.
Assess Eligibility
The Tax Administration Act requires that disclosures meet specific requirements, including being voluntary, complete, and accurate.
Evaluate Historical Exposure
A proper review should assess the potential impact of tax shortfalls, administrative penalties, understatement penalties and interest.
Establish Long-Term Compliance
The objective should not only be to resolve historical matters but to ensure robust compliance processes going forward.
Why Businesses Choose TCS Advisory & Compliance
At TCS Advisory & Compliance, we work as a strategic partner to finance teams, business owners and corporate decision-makers.
Our approach focuses on identifying risk, resolving historical non-compliance and creating sustainable compliance frameworks that support long-term growth.
Some of our specialist tax service offerings include:
With two decades of specialist experience and a strong track record of successful VDP applications, we help businesses navigate complex compliance matters with confidence while reducing unnecessary risk exposure.
Contact us to make a booking.
Mobile: +27 (0) 66 239 4045
Email: info@taxcs.co.za
Address: Ground Floor Building 4, Quadrum Office Park, 50 Constantia Blvd, Constantia Kloof, Gauteng, South Africa, 1709