⋆
TAX3704: Tax Administration
OCT/NOV Examination 2026 Revision Guide
Covers Past Papers: Oct/Nov 2023, 2024 & 2025
⋆ ⋄ ⋆ ⋄ ⋆ ⋄ ⋆
South African Tax Administration Act 28 of 2011
Exam Revision Guide
Module Code: TAX3704
Module Name: Tax Administration
Papers Covered: Oct/Nov 2023, 2024 & 2025
Prepared for: Oct/Nov 2026 Examination
Total Marks: 100 marks per sitting
Legislation: Tax Administration Act 28 of 2011
Know the Act. Know the process. Know the deadlines.
,TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
How to Use This Guide
This document covers the major examination question areas that appear across the TAX3704
Oct/Nov 2023, Oct/Nov 2024, and Oct/Nov 2025 papers. Every question is written in the
style UNISA examiners use, and the answers are calibrated to mark allocations. Work through
each section actively — don’t just read; cover the answer box and attempt the question first.
Legislation: The Tax Administration Act 28 of 2011 (“TAA”) governs almost every topic in
this module. Know the section numbers — examiners reference them directly.
Structure of TAX3704 exams: Typically three to four compulsory questions covering reg-
istration, returns, assessments, objections and appeals, penalties, interest, SARS powers, and
dispute resolution. Questions range from short definitions (4–8 marks) to extended case-study
calculations (25–30 marks).
Page 2 of 44 ⋆
,TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
EXAMINATION PAPER: OCT/NOV 2025
Total: 100 Marks • All questions compulsory
Question 1 [30 marks]
(a) [10 marks]
Question: Ayanda Molefe is a South African resident who recently started a small
landscaping business. He has not yet registered with the South African Revenue Service
(SARS). His accountant tells him he needs to register for income tax and VAT.
(i) Briefly explain the duty of a person to register as a taxpayer under the Tax Adminis-
tration Act 28 of 2011 (TAA). (4)
(ii) List any FOUR categories of persons or entities that are required to register as tax-
payers under the TAA. (4)
(iii) Explain what SARS may do if Ayanda fails to register voluntarily. (2)
Answer:
(i) Duty to register (section 22 TAA):
Any person who is liable to pay a tax must apply to be registered with SARS in the manner
and within the period prescribed by the rules. Registration is not optional where a legal obli-
gation to pay tax exists — it applies as soon as the liability arises, not when the person first
actually pays tax.
Key Concept
Section 22 TAA imposes a duty on any person who becomes liable to pay tax to
apply for registration. SARS may also register a person who has not registered volun-
tarily.
(ii) Four categories required to register:
• Natural persons resident in South Africa who derive taxable income above the tax thresh-
old
• Companies (including close corporations and personal service providers) that are tax-
resident in South Africa
• Trusts that carry on business or derive taxable income in South Africa
Page 3 of 44 ⋆
,TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
• Employers who are required to deduct employees’ tax (PAYE) from remuneration paid
to employees
(iii) SARS’s power to register a person without application:
Under section 22(3) of the TAA, if a person fails to register voluntarily, SARS may register
that person on the basis of information available to it. SARS issues a registration number
to the taxpayer and notifies them. The taxpayer is then bound by all obligations that flow
from registration — filing returns, paying assessed tax, and any applicable penalties for non-
compliance.
Watch Out!
Failure to register does not erase the underlying tax liability. SARS can still assess
back-taxes, impose administrative penalties, and charge interest on late payment.
(b) [10 marks]
Question: Briefly define each of the following types of assessments under the TAA, and
state the legal basis (section) for each one:
(i) Original assessment (2)
(ii) Additional assessment (2)
(iii) Reduced assessment (2)
(iv) Jeopardy assessment (2)
(v) Estimated assessment (2)
Answer:
Definition Legal Basis
Type
The first assessment issued for s 92 TAA
Original assess-
a tax period, normally based
ment
on the taxpayer’s return.
Issued when SARS discovers s 92 TAA
Additional assess-
that an original assessment
ment
understated the taxpayer’s
liability; can only increase the
liability.
Page 4 of 44 ⋆
,TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
Definition Legal Basis
Type
Issued to decrease a previous s 93 TAA
Reduced assess-
assessment, typically after
ment
SARS accepts an objection or
where an error is found.
Issued before the normal filing s 94 TAA
Jeopardy assess-
date where SARS believes
ment
the taxpayer intends to leave
South Africa or dissipate as-
sets, making collection of tax
at risk.
Issued when a taxpayer fails to s 95 TAA
Estimated assess-
submit a return or to provide
ment
information; SARS estimates
the taxable amount based on
available information.
Exam Tip
Know the section number for each assessment type. Examiners deduct marks for citing
the wrong section. Also note: a jeopardy assessment can be issued even before the tax
becomes due, which is the key distinguishing feature.
(c) [10 marks]
Question: Priya Naidoo, a salaried employee, received a notice of assessment (ITA34)
from SARS showing additional tax of R45 000. She believes the assessment is incorrect
and wants to dispute it.
(i) Explain the objection process Priya must follow, including the relevant time period.
(5)
(ii) What happens if SARS does not respond to Priya’s objection within the prescribed
period? (3)
(iii) Name TWO grounds that would make an objection invalid. (2)
Answer:
Page 5 of 44 ⋆
, TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
(i) The objection process (sections 104–107 TAA and Dispute Resolution Rules):
• Priya must lodge her objection within 80 business days of the date of the assessment
(section 104(4)).
• The objection must be submitted in the prescribed form (NOO – Notice of Objection) via
SARS eFiling, the SARS MobiApp, or at a SARS branch.
• The objection must state the grounds of the objection and the specific amount she dis-
putes. Vague or blanket objections are invalid.
• SARS must decide the objection within 60 business days of receiving a valid objection
(Rule 60 of the Dispute Resolution Rules).
• SARS may allow, partially allow, or disallow the objection and must give reasons for a
disallowance.
(ii) If SARS does not respond within the prescribed period:
If SARS fails to respond within 60 business days (or the extended period where applicable),
the objection is treated as deemed to be disallowed (Rule 60(5)). Priya may then proceed
to lodge an appeal against the deemed disallowance without waiting further.
(iii) Two grounds that invalidate an objection:
• The objection is submitted outside the prescribed time period (80 business days)
without SARS granting a condonation (extension).
• The objection is not in the prescribed form or does not disclose the grounds of objec-
tion (i.e., it is a blanket objection without specifying what is disputed and why).
Example
If Priya simply writes “I disagree with this assessment” without stating what the error
is, SARS will treat the objection as invalid. She must say specifically: “The assessment
erroneously included a director’s fee of R45 000 as taxable income; this amount was a
loan repayment and not income.”
Page 6 of 44 ⋆
TAX3704: Tax Administration
OCT/NOV Examination 2026 Revision Guide
Covers Past Papers: Oct/Nov 2023, 2024 & 2025
⋆ ⋄ ⋆ ⋄ ⋆ ⋄ ⋆
South African Tax Administration Act 28 of 2011
Exam Revision Guide
Module Code: TAX3704
Module Name: Tax Administration
Papers Covered: Oct/Nov 2023, 2024 & 2025
Prepared for: Oct/Nov 2026 Examination
Total Marks: 100 marks per sitting
Legislation: Tax Administration Act 28 of 2011
Know the Act. Know the process. Know the deadlines.
,TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
How to Use This Guide
This document covers the major examination question areas that appear across the TAX3704
Oct/Nov 2023, Oct/Nov 2024, and Oct/Nov 2025 papers. Every question is written in the
style UNISA examiners use, and the answers are calibrated to mark allocations. Work through
each section actively — don’t just read; cover the answer box and attempt the question first.
Legislation: The Tax Administration Act 28 of 2011 (“TAA”) governs almost every topic in
this module. Know the section numbers — examiners reference them directly.
Structure of TAX3704 exams: Typically three to four compulsory questions covering reg-
istration, returns, assessments, objections and appeals, penalties, interest, SARS powers, and
dispute resolution. Questions range from short definitions (4–8 marks) to extended case-study
calculations (25–30 marks).
Page 2 of 44 ⋆
,TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
EXAMINATION PAPER: OCT/NOV 2025
Total: 100 Marks • All questions compulsory
Question 1 [30 marks]
(a) [10 marks]
Question: Ayanda Molefe is a South African resident who recently started a small
landscaping business. He has not yet registered with the South African Revenue Service
(SARS). His accountant tells him he needs to register for income tax and VAT.
(i) Briefly explain the duty of a person to register as a taxpayer under the Tax Adminis-
tration Act 28 of 2011 (TAA). (4)
(ii) List any FOUR categories of persons or entities that are required to register as tax-
payers under the TAA. (4)
(iii) Explain what SARS may do if Ayanda fails to register voluntarily. (2)
Answer:
(i) Duty to register (section 22 TAA):
Any person who is liable to pay a tax must apply to be registered with SARS in the manner
and within the period prescribed by the rules. Registration is not optional where a legal obli-
gation to pay tax exists — it applies as soon as the liability arises, not when the person first
actually pays tax.
Key Concept
Section 22 TAA imposes a duty on any person who becomes liable to pay tax to
apply for registration. SARS may also register a person who has not registered volun-
tarily.
(ii) Four categories required to register:
• Natural persons resident in South Africa who derive taxable income above the tax thresh-
old
• Companies (including close corporations and personal service providers) that are tax-
resident in South Africa
• Trusts that carry on business or derive taxable income in South Africa
Page 3 of 44 ⋆
,TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
• Employers who are required to deduct employees’ tax (PAYE) from remuneration paid
to employees
(iii) SARS’s power to register a person without application:
Under section 22(3) of the TAA, if a person fails to register voluntarily, SARS may register
that person on the basis of information available to it. SARS issues a registration number
to the taxpayer and notifies them. The taxpayer is then bound by all obligations that flow
from registration — filing returns, paying assessed tax, and any applicable penalties for non-
compliance.
Watch Out!
Failure to register does not erase the underlying tax liability. SARS can still assess
back-taxes, impose administrative penalties, and charge interest on late payment.
(b) [10 marks]
Question: Briefly define each of the following types of assessments under the TAA, and
state the legal basis (section) for each one:
(i) Original assessment (2)
(ii) Additional assessment (2)
(iii) Reduced assessment (2)
(iv) Jeopardy assessment (2)
(v) Estimated assessment (2)
Answer:
Definition Legal Basis
Type
The first assessment issued for s 92 TAA
Original assess-
a tax period, normally based
ment
on the taxpayer’s return.
Issued when SARS discovers s 92 TAA
Additional assess-
that an original assessment
ment
understated the taxpayer’s
liability; can only increase the
liability.
Page 4 of 44 ⋆
,TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
Definition Legal Basis
Type
Issued to decrease a previous s 93 TAA
Reduced assess-
assessment, typically after
ment
SARS accepts an objection or
where an error is found.
Issued before the normal filing s 94 TAA
Jeopardy assess-
date where SARS believes
ment
the taxpayer intends to leave
South Africa or dissipate as-
sets, making collection of tax
at risk.
Issued when a taxpayer fails to s 95 TAA
Estimated assess-
submit a return or to provide
ment
information; SARS estimates
the taxable amount based on
available information.
Exam Tip
Know the section number for each assessment type. Examiners deduct marks for citing
the wrong section. Also note: a jeopardy assessment can be issued even before the tax
becomes due, which is the key distinguishing feature.
(c) [10 marks]
Question: Priya Naidoo, a salaried employee, received a notice of assessment (ITA34)
from SARS showing additional tax of R45 000. She believes the assessment is incorrect
and wants to dispute it.
(i) Explain the objection process Priya must follow, including the relevant time period.
(5)
(ii) What happens if SARS does not respond to Priya’s objection within the prescribed
period? (3)
(iii) Name TWO grounds that would make an objection invalid. (2)
Answer:
Page 5 of 44 ⋆
, TAX3704 | Tax Administration – Exam Revision Oct/Nov 2023–2025
(i) The objection process (sections 104–107 TAA and Dispute Resolution Rules):
• Priya must lodge her objection within 80 business days of the date of the assessment
(section 104(4)).
• The objection must be submitted in the prescribed form (NOO – Notice of Objection) via
SARS eFiling, the SARS MobiApp, or at a SARS branch.
• The objection must state the grounds of the objection and the specific amount she dis-
putes. Vague or blanket objections are invalid.
• SARS must decide the objection within 60 business days of receiving a valid objection
(Rule 60 of the Dispute Resolution Rules).
• SARS may allow, partially allow, or disallow the objection and must give reasons for a
disallowance.
(ii) If SARS does not respond within the prescribed period:
If SARS fails to respond within 60 business days (or the extended period where applicable),
the objection is treated as deemed to be disallowed (Rule 60(5)). Priya may then proceed
to lodge an appeal against the deemed disallowance without waiting further.
(iii) Two grounds that invalidate an objection:
• The objection is submitted outside the prescribed time period (80 business days)
without SARS granting a condonation (extension).
• The objection is not in the prescribed form or does not disclose the grounds of objec-
tion (i.e., it is a blanket objection without specifying what is disputed and why).
Example
If Priya simply writes “I disagree with this assessment” without stating what the error
is, SARS will treat the objection as invalid. She must say specifically: “The assessment
erroneously included a director’s fee of R45 000 as taxable income; this amount was a
loan repayment and not income.”
Page 6 of 44 ⋆
