Professional Certificate in Tax Opinion and Dispute Writing

Date: Apr 15, 2020 - Jul 31, 2020

Application fee: R450.00

Once-off: R13,950.00

Lecturer: Prof. Piet Nel CA(SA)
Lecturer: Prof. Keith Engel

The purpose of this professional certificate is to develop the critical research, problem solving and writing skills to draft TAA compliant tax opinions that will mitigate SARS penalty risk. The course will also equip participants to effectively respond to SARS letter of audit findings, prepare technical sound SARS objections and appeals.

Course overview

The course covers areas of tax research and internal issue memoranda, advisory opinions and controversy.

Course delivery

Each part will contain an initial lecture via The Tax Faculty virtual classroom, two practical assignments and two reflective

virtual classrooms to develop critical thinking skills. Topics for assignments will be given to course

participants with all participants responding to the same assignments. All assignments will be independently

marked and certificates are awarded based on assignments submitted.

This professional certificate is delivered by The Tax Faculty through the virtual campus and webinar platforms.

Admission requirements

A minimum of BCom or LLB degree. Completed three years structured work experience in tax, accounting, law or five years unstructured experience.

Assessment and award of certificate

Successful completion of the course requires an average mark of 50% for all assignments.

Upon completion, successful candidates will receive a Certificate from The Tax Faculty.

What you will learn

Module 1: Fundamentals of tax research 

The first module will be dedicated to the fundamentals associated with tax research. 

Successful tax professionals need to understand the various sources for research as generated by the various arms of government, such as National Treasury (tax legislation and policy), SARS (interpretation and administration) and case law.

Academic and international research will also be considered for supplementary consideration. The lecture pertaining to this part of the course will be followed by practical assignments.

The first assignment will involve introductory research questions and answers that can be readily obtained from various sources.
The second assignment will require a short memorandum describing the nature of law and interpretation related to issues/problems with less precise solutions and outcomes.

The third assignment will focus on issues with useful indicators that can best be found in local tax legislative history.

Module 2: Tax opinions: Developing a position and principles of opinion writing 

The second part of the course will be dedicated to opinion writing. Course participants will learn how to write in terms of assessing risk as opposed to definitive conclusions. This part of the course will include discussions pertaining to the role of opinions in terms of penalties (e.g. section 223 opinions). The lecture will also cover general recurring doctrines (e.g. application of the general anti-avoidance rule and the substance-over-form). The lecture pertaining to this part will be followed by assignments involving practical opinion writing.

The first assignment will entail the writing of an opinion associated with a tax return. Participants will be requested to assess the risk associated with the position as well as whether an accounting provision will be required for financial purposes.

The second assignment will be associated with an advisory opinion in terms of setting up a proposed structure. Course participants will be expected to assess various technical risks and outcome probabilities.

The third assignment will be associated with the steps involving a series of transactions. Participants will be expected to prepare a step memorandum as well as an opinion detailing key risks. This assignment will include considerations relating to anti-avoidance doctrines.  

Module 3: Controversy writing

The third part of the course will be dedicated to the initial stages of taxpayer-SARS controversy. 

This process starts with the phase of initial queries and responses. These queries and responses often escalate in assessments, objections and appeals. Writing of this nature is as much about procedure as about substance. Both the relevant portions of the Tax Administration Act and the Promotion of Administrative Justice Act will be considered. The lecture to this final part will be followed by assignments relating to the various documents arising during the initial stages of tax controversy.

The first assignment will entail the writing of a response to a SARS information request and the review of a related document of SARS findings. Trainees are expected to analyse information available for appropriate disclosure while protecting taxpayer rights.

The second assignment will entail the writing of an objection to a SARS assessment as well as a corresponding request for suspension of payment. Participants are expected to defend the taxpayer’s position in terms of substance and process.

The third assignment will entail the writing of an appeal along with a side memorandum providing advice as to a reasonable compromise based on a probable outcome of risks. Course participants are expected to best argue the taxpayer’s position but also retain the ability to best advise the client on whether to compromise based on the taxpayer’s likelihood of success.

Flexible payment options

Payment option 1: Once-off payment 

R13 950.00 (incl. VAT).

Payment option 2: Debit order

Application fee (Non-refundable): R450 (incl. VAT).

Three installments: R5 348.00 per month (incl. VAT).
Total: R16 044.00 (incl. VAT).

Payments and cancellations

  • All required minimum payments must be made by direct EFT or by credit card before the commencement of a course.
  • Kindly note that should debit order payment terms not be adhered to; legal action will be taken.
  • Proof of payment may be requested before access to the iLearn platform will be communicated, should your payment not reflect on The Tax Faculty’s bank account.
  • Only written notice of cancellation will be accepted.


  • If the cancellation is requested more than 10 working days prior to the course, no cancellation fee will be applicable.
  • If the cancellation occurs less than 10 working days prior to the event a 100% cancellation fee will be applicable.
  • Students who register for a course and fail to attend will be held liable for the full course fee.
  • Course application fee is non-refundable.
  • CPD event delegates who book and fail to attend will be held liable for the full event fee.
  • The Tax Faculty’s liability in the case of a course being cancelled will be limited to a refund of the course fee.

For courses with a six-month (or longer) rollout the following will apply:

  • Should a cancellation be received within six weeks of the course start date, the student will still be liable for 50% of the semester cost.
  • Should the cancellation be received after six weeks of the course start date, the student will be liable for the full semester cost.
  • Students may defer during a six-month course to any other course with a rollout planned for longer than six months.
  • The course application fee is non-refundable.

Why wait?

Get your application in to avoid disappointment. Click below to start your application.

Save this course to your Google or Outlook calendar.

Explore Smarty