SARS updates delivery channels for tax dispute documents
SARS updates delivery channels for tax dispute documents
By Seelan Muthayan, Partner
SARS has issued Public Notice No. 7663 in Government Gazette No. 54941, dated 3 July 2026, prescribing where and how documents, notices and requests must be delivered for purposes of the dispute resolution rules made under section 103 of the Tax Administration Act, 2011. The Notice took effect on publication and supersedes Public Notice No. 5114 of 8 August 2024.
Key takeaway
The new notice is primarily procedural. It does not alter the substantive rights available to taxpayers in objections, appeals or related tax dispute proceedings. Its importance lies in identifying the correct electronic and physical channels for engaging with SARS, the Tax Board and the Tax Court.
Taxpayers, tax practitioners and legal representatives should therefore ensure that dispute-related correspondence is submitted through the prescribed channels. Using an outdated address or incorrect delivery method may create avoidable procedural risk, particularly where statutory time periods are running.
Requests for reasons, objections and appeals
For the ordinary dispute process, the Notice confirms that documents relating to requests for reasons, objections and appeals should generally be delivered through the taxpayer’s eFiling profile on the SARS eFiling platform.
A different submission route applies where the dispute concerns any of the following matters:
- Estate duty;
- Donations tax;
- Imported services supplied to non-vendors;
- Rejection of a VAT registration application; or
- Paragraph 13(1) of the First Schedule to the Income Tax Act.
In these cases, the request for reasons, ADR1 objection or ADR2 appeal must be submitted to contactus@sars.gov.za.
If eFiling or the designated email address is unavailable, the Notice allows delivery to be arranged at a SARS branch office, but only after an appointment has been made.
Tax board appeals
Once an appeal proceeds before the Tax Board, documents, notices and requests delivered after the notice of appeal must be sent to the regional Tax Board email address applicable to the taxpayer’s area, or delivered to the relevant clerk of the Tax Board at the prescribed physical address. The notice updates the contact details for the relevant regional offices, including Gauteng, Western Cape, KwaZulu-Natal, Eastern Cape, Free State, Northern Cape, Limpopo, Mpumalanga and North West.
Separate contact details apply to taxpayers managed by SARS’ Large Business and International (LBI) Unit and High Net-Worth Individuals (HNWI) Unit, who must use the dedicated email or physical addresses specified in the Notice.
Tax court proceedings
The Notice also deals with delivery in Tax Court-related proceedings, including applications brought under the dispute resolution rules and appeals that have progressed to the Tax Court.
Applications under rules 52 and 56
Applications and notices under Part F of the dispute resolution rules must be delivered electronically to both SARS and the Registrar of the Tax Court using the relevant email addresses set out in the notice, or physically at the prescribed Pretoria addresses.
Tax court appeals
After a Tax Court appeal has been instituted, appeal-related documents must similarly be delivered to both SARS and the Registrar of the Tax Court using the contact details specified in the notice.
Registrar of the tax court
Documents intended for the Registrar of the Tax Court may be sent electronically to RegistrarTaxCourt@sars.gov.za or delivered physically to the Registrar’s offices at the Landbank Building, Nieuw Muckleneuk, Pretoria.
Important exclusions
The Notice expressly states that it does not apply to:
- Proceedings under customs and excise legislation, which remain subject to the requirements of section 96 of the Customs and Excise Act and the related rules; or
- Causes of action against SARS that do not arise from the administration of a Tax Act.
Practical implications
Taxpayers and advisers should update precedent documents, dispute-filing workflows and litigation checklists to reflect the latest delivery requirements. Although the Notice is administrative in character, delivery rules matter in practice. Tax dispute procedures under the TAA are time-sensitive, and non-compliance with prescribed delivery channels may give rise to unnecessary disputes about whether a filing was validly made.
Our view: Public Notice No. 7663 is a useful reminder that tax disputes are not only matters of technical tax law, but also of procedural discipline. Taxpayers should confirm the correct delivery channel before submitting objections, appeals, applications or court-related documents, particularly where deadlines are imminent or where a matter falls within one of the categories requiring email submission rather than eFiling.