Rule 6 of the rules gazetted under section 103 of the Tax Administration Act, No. 28 of 2011 allows taxpayers to ask for reasons for an assessment or a SARS decision.

A request for reasons under rule 6 of the rules, if well drafted, serves not only to ring-fence the issues in dispute but can also serve to secure a strategic advantage in the rest of the dispute.

Asking for reasons and understanding the nature of the reasons that can be expected under the law is crucially important in a tax dispute.