High Court Upholds Tax Court Ruling: Payroll Service Provider Not Liable for SDL and VAT

• The South African Revenue Service posted a High Court Judgment for Case No. CA 118/2024 on September 3.
• The case clarified liability for skills development levies and VAT for payroll administration services.
• The taxpayer provided payroll administration services to mid-market retail businesses.
• The Tax Agency claimed the personnel were the taxpayer’s employees and conducted an audit.
• The audit resulted in additional SDL and VAT assessments.
• The Tax Court ruled the taxpayer was not the employer but acted as an agent for the retail clients.
• The High Court upheld the Tax Court’s decision on appeal.
• The taxpayer successfully proved that the additional assessments were not due.

Source: news.bloombergtax.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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