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Two former SARS officials thought handing in their resignations was a clean exit from a corruption scandal. SARS had other plans.

The Court Order That Changed Everything

Using section 163 of the Tax Administration Act, SARS applied to the Gauteng Division of the High Court in Pretoria — and won. The result: a preservation order freezing the assets of both ex-officials before they could move a cent.

One official resigned in 2024, the other in 2025. Neither anticipated that a resignation letter would mean nothing in the face of a High Court order.

What Was Seized

The list of assets now frozen is striking:

  • Three immovable properties

  • Six vehicles

  • Multiple bank and investment accounts across major financial institutions.

The total estimated value: several million rand. None of it can be sold or transferred without court authorisation. The court also appointed a curator bonis, not just to lock down known assets, but to actively search for anything that may have been hidden or moved beyond SARS's reach.

What They're Accused Of

SARS presented prima facie evidence of serious wrongdoing, including corruption, money laundering, unauthorised work outside SARS, breach of SARS secrecy provisions, and abuse of state property. These weren't admin errors. They were deliberate acts carried out to enrich individuals at the expense of the public.

Acting Commissioner Dr Johnstone Makhubu put it bluntly:

Those who think that resignation will exculpate them from the consequences of their actions must know that they’ll be pursued and will be found wherever they are.

The Bigger Picture

This action falls under SARS's Illicit Economy Strategy, which gives effect to the President's commitments in the State of the Nation Address. Corruption inside government departments is now a named, high-priority target.

It also continues a clear enforcement trend. As covered in our article on SARS raiding insiders in a corruption crackdown, the revenue authority is no longer waiting for issues to surface. It is actively hunting them, with legal tools, intelligence, and court orders ready to deploy.

What This Means for Your Practice

The Tax Administration Act allows SARS to freeze assets before a tax assessment is even finalised. That's a powerful and fast-moving tool, and it applies well beyond corruption cases. If any of your clients carry unresolved tax exposure or hold complex asset structures, the time to advise them is now. Not when the preservation order lands on their doorstep.

SARS is cleaning its own house. That same energy is being directed outward. Make sure your clients are ready.

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SARS Makes Trust Return Penalties Official — The Clock Is Now Ticking