Taxpayer MPT vs SARS – just how correct was the ‘royal we’?
Overview
A summary of the Taxpayer MPT v Commissioner for the South African Revenue Service (IT 46010) [2025] ZATC 11 (5 September 2025) case in which the court had to decide whether SARS’ imposition of additional royalties was as a result of correct interpretation of the law on their part.
| Author | SAICA (Nomvula Masehla: Lead) |
|---|---|
| Division | Tax |
| Keywords | royalties EBT Interpretation contra fiscum |
| Categories | Tax |
| Date | 1 December 2025 |