How South African courts are redefining tax relief and social contracts
African News Agency | 12.04.2026 14:35
In the last five years, a quiet but important shift has taken place in our rebate and refund jurisprudence. South African courts – especially in the diesel and fuel levy space – have started to speak about these relief measures as if they were “privileges”, exceptional concessions that taxpayers must earn through near-perfect formal compliance. You see this very clearly in CSARS v Glencore Operations SA (Pty) Ltd, and then, more starkly, in the Constitutional Court’s recent Tholo Energy Services CC v CSARS judgment.
