What questions should I answer or ask before responding to a SARS audit letter?

How to use this guide

These questions are not a general SARS FAQ. Their purpose is to close decisions before drafting starts. The retained first-response guide owns notice authentication and the overall sequence. This page owns the answer log that coordinates the taxpayer, internal finance team, accountant, registered tax practitioner and any lawyer.

Build a dated answer log

Use one row per question. Record:

• the question and why it affects the response;
• the current answer;
• the evidence supporting that answer;
• the person responsible for confirming it;
• the date and source of confirmation;
• any assumption or limitation;
• whether written SARS clarification is required;
• the reviewer and sign-off state; and
• the next action if the answer changes.

An answer such as “the accountant knows” is not closed. Link it to the letter, return, ledger, source record, mandate, written instruction or correspondence that supports it. Keep uncertain answers visibly open rather than letting them become hidden assumptions in the draft.

1. What exact process and letter is this?

Ask:

• Is the communication visible in official SARS correspondence or otherwise authenticated?
• Is it a request during verification, a referral for audit, a Notification of Audit, a request for relevant material, a field-audit arrangement, an Audit Findings Letter, or an assessment or demand?
• Has an auditor been allocated?
• What action does the letter require now?
• What later event does the letter say may follow?

SARS distinguishes verification from audit. It also says a referral for audit is not itself the start of an audit; the Notification of Audit marks the start and identifies the allocated auditor. Do not import objection-stage language merely because the taxpayer disagrees with the audit direction. If the process cannot be identified from the letter, retrieve the official correspondence and seek clarification through an official channel.

2. What is the actual scope?

Create a scope statement with:

• taxpayer or entity;
• tax reference and case reference;
• tax type;
• period or periods;
• return, declaration or transaction;
• issue, line item or risk identified;
• exact information or documents requested;
• delivery channel; and
• stated due date and time.

Then ask whether any requested item appears ambiguous, duplicated, unavailable, held by a third party or outside the team’s understanding of the stated scope. Asking SARS to clarify does not guarantee that SARS must narrow the request, and a clarification request does not automatically pause the deadline. Record the request, keep working on the uncontested items and preserve the response received.

3. Who owns every evidence item?

For each request, answer:

• Which system or custodian holds the original?
• Is the record available for the correct period and entity?
• Is it an original source, presentation copy, reconstruction, calculation or explanation?
• Who can verify provenance and completeness?
• Does it contain third-party or sensitive information?
• Is a readable export possible without changing the source?
• What is the recovery plan if it is missing?

The objective is responsibility, not a generic shopping list. Once the evidence set is known, use the source-document organisation guide to build the request matrix, version structure and submission manifest.

4. How does the filed position reconcile?

Ask the preparer and reviewer:

• Which return or declaration version was actually filed?
• Which computation or schedule produced the figure in question?
• Does it agree to the trial balance, ledger, payroll, VAT records or other relevant system?
• Can each material entry be traced to source evidence?
• Are dates and tax periods aligned?
• Are there reversals, journals, duplicates, estimates or cut-off differences?
• Does SARS or a third-party dataset appear to use a different population?
• Which differences remain unexplained?

Do not force the records to match. A reconciliation should expose the difference, quantify it where possible and identify the analysis required. If different advisers use different figures, assign one owner to resolve the conflict before the response text is approved.

5. Is this an explanation, correction or legal-position issue?

An evidence gap, a clerical difference, an accounting treatment and a contested interpretation are not the same problem. Ask:

• Does the filed position remain factually and technically supported?
• Is a Request for Correction available and appropriate at this stage, or would it create a different consequence?
• Is the issue an explanation of the existing position rather than a change to it?
• Could the wording be treated as an admission about conduct, intention or non-compliance?
• Does the issue raise a possible voluntary disclosure, penalty, personal-liability or offence question?
• Who is authorised to make the decision?

Do not choose a correction, VDP, objection or complaint route as a drafting convenience. Record the unresolved decision and escalate it before communicating a substantive position.

6. Who has authority and who signs off?

Ask:

• Who is the taxpayer, public officer, registered representative or authorised internal decision-maker?
• Who may give instructions to the accountant, tax practitioner or lawyer?
• Is the eFiling user permitted to access and submit for the relevant entity and tax type?
• Which adviser is responsible for facts, calculations, tax treatment, legal issues and final wording?
• Who approves each schedule and the overall response?
• Who completes the actual submission and monitors follow-up correspondence?

Using a registered tax practitioner or lawyer does not transfer every factual responsibility away from the taxpayer. Define the adviser’s scope and the taxpayer’s sign-off. If someone is providing tax services for reward, verify the applicable SARS registration rather than relying on a title alone.

7. Does any material require a separate confidentiality or privilege decision?

Ask:

• Is the item within the request and relevant to the issue being addressed?
• Does it contain third-party personal, employee, customer or commercially sensitive information?
• Is redaction proposed, and who has confirmed that the remaining record still proves the point?
• Is the material a pre-existing source record, an accountant's file, legal advice or a communication created for a legal-advice purpose?
• Could disclosure waive a legitimate privilege claim?
• Is a written legal view needed before production?

Do not assume POPIA or confidentiality defeats a SARS request. Do not assume every document held by an accountant or lawyer is privileged. Separate the material for review, document the decision and avoid an unexamined bulk upload.

8. What delivery controls apply?

Ask:

• What does the authentic letter specify as the channel?
• Is the submission link active for the correct taxpayer, tax type and period?
• What file formats, sizes and counts does the current work page accept?
• Will a cover index or multiple bundles be needed?
• When must the internal draft, technical review and authorisation be complete?
• What proves upload and what proves final submission?
• Where will the exact sent set and receipt be archived?

Do not hard-code a general upload limit from an unrelated tax type. SARS's public verification page gives current operational limits for that route, but the letter and live work page remain the practical control for the specific response.

Questions that may need a written SARS answer

Where the letter is unclear, a concise written clarification request can identify:

• the exact item or wording requiring clarification;
• the taxpayer, tax type and period;
• the team’s present understanding;
• the specific ambiguity or unavailable format;
• any proposed alternative evidence or delivery method;
• whether more time is requested and why; and
• the uncontested work that continues meanwhile.

Avoid open-ended questions such as “What do you want?” Ask a defined question that can be answered and archived. Do not treat silence as approval, a narrowed scope or an extension.

Questions for advisers

Ask the accountant or registered tax practitioner:

• Which figures and records have been reconciled?
• Which assumptions remain?
• Does the response explain or change the filed position?
• Which technical tax issues require a written conclusion?
• What is outside the engagement?

Ask a tax lawyer where appropriate:

• Is the procedural stage and response route correctly identified?
• Does the request raise relevance, scope, privilege or compelled-information issues?
• Could the draft wording affect penalties, personal exposure, VDP options or a suspected offence?
• Which facts and records must remain separate from legal advice?
• What decision must be made before submission?

The audit-specific tax-lawyer escalation guide explains when this extra legal layer may be proportionate. It does not replace accounting reconciliation or registered tax-practitioner work.

Close the log before drafting and again before release

The first close confirms that the team knows what it is responding to, what evidence is owned and what decisions require escalation. The second close confirms that later facts did not change those answers. Any change to scope, figures, authority, confidentiality treatment or deadline should reopen the affected decision and identify the new approver.

Do not relabel this pre-assessment answer log as an objection. If an assessment is later issued, the SARS objection questions guide owns the different remedy stage.

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