Quick answer
Organise the file around each disputed item, not around the order in which documents happened to arrive. Begin with an authority and deadline folder, then create one evidence folder for every source code, adjustment, penalty or legal issue. A master schedule should connect the assessed amount, proposed correction, factual proposition, legal ground and supporting exhibit.
How to use this guide
Keep original source records separate from calculations and drafted submissions. Preserve what SARS already received, label what is new, and maintain a final filing copy with proof of delivery. This structure helps an accountant verify the numbers and a tax lawyer test whether the evidence actually proves the proposed ground.
Folder 01: authority, decision and time
Place the notice of assessment or other objectionable decision first. Add the eFiling correspondence entry, delivery notification, audit findings, SARS grounds, tax period and case number. Create a one-page control sheet recording the taxpayer's legal name, tax reference, decision date, date accessed, payment due date and every possible dispute trigger.
If reasons were requested under rule 6, keep the prescribed request, its receipt, SARS's response and the date that response was delivered in this folder. The ordinary objection period is generally 80 business days, but the start changes depending on the reasons process. The file should allow a reviewer to reproduce the calculation without relying on a calendar note.
Include the representative's mandate, submission authority and eFiling access status. Where a manual channel applies, retain the address prescribed for delivery. Keep a separate late-objection subsection if condonation may be required, with dated proof supporting each part of the delay chronology.
Folder 02: the disputed-item register
Create a spreadsheet or table with one row per disputed item. Useful columns are:
- assessment line, source code or transaction identifier;
- SARS's amount and stated ground;
- taxpayer's proposed amount and treatment;
- difference in rand;
- factual proposition that must be proved;
- legal ground relied on;
- exhibit numbers;
- whether SARS has already received each exhibit; and
- reviewer, status and unresolved question.
Reconcile the sum of the rows to the assessment before drafting. If an adjustment affects several periods, provide a period-by-period bridge rather than a net number. If one document supports multiple rows, link to the same controlled exhibit instead of storing altered copies under different names.
The register is not itself proof. Its purpose is to show why each attached record matters and expose gaps. Mark an entry “unverified” where the source has not been located instead of converting an assumption into a fact.
Folder 03 onward: evidence by issue
Give each disputed item its own folder with a short evidence note. Put primary records before summaries: signed agreements, tax invoices, bank statements, payroll reports, customs entries, contemporaneous correspondence, asset records or other documents relevant to the ground. Then add the accountant's reconciliation and any explanatory statement.
Use stable exhibit numbers such as D01-001 rather than renumbering files whenever something is inserted. Record the original filename, author or issuer, date, period and source system. Where only a scan exists, keep the clearest copy and note where the original is held.
Do not silently repair a source document. If an invoice was later corrected, preserve both versions and explain the correction. If a calculation was rebuilt from exported data, retain the raw export, the transformation steps and the output. A reviewer should be able to trace the proposed tax result back to unaltered evidence.
Separate calculations from legal submissions
Place returns, ledgers, trial balances, reconciliations and computation work papers in a calculations folder. The accountant should provide a tie-back showing how the proposed figure moves from source records through the relevant tax calculation to the return or assessment line.
Store draft grounds, legal research and advice in a different workspace. Legal professional privilege does not automatically protect accountant communications or ordinary business records. A privileged legal memorandum should not be embedded in a workbook intended for SARS. If privilege is asserted over material requested by SARS, section 42A of the Tax Administration Act provides a process for resolving that claim; document-specific advice may be necessary.
This separation is not a device for withholding relevant evidence. It prevents accidental circulation of legal advice and makes it easier to deliver the substantiating documents required for the objection without exposing unrelated sensitive material.
Record what SARS already has
Rule 7 calls for substantiating documents not previously delivered for purposes of the disputed assessment. Build a delivery ledger showing the date, channel, case reference, document name and receipt for every earlier submission. Copy the exact delivered set into a read-only folder.
Where an earlier upload is incomplete or illegible, flag it and explain the replacement. Do not assume SARS can retrieve a document from an unrelated case. Conversely, avoid flooding the objection with repeated statements and hundreds of unindexed pages that obscure the evidence for each ground.
If SARS requests additional substantiating documents under rule 8, open a new response subfolder and preserve the notice because it creates its own delivery period. Map each requested item to the supplied file or explain accurately why it is unavailable.
Prepare the filing bundle
Create a clean export containing the prescribed objection form, detailed grounds, disputed-item schedule and only the supporting exhibits relied on. Check page orientation, searchability, legibility, file size and password settings. Remove duplicate scans but never discard the preserved originals.
Use an attachment index that states the ground supported by each exhibit. Compare every figure in the form with the final register. Ask a second reviewer to test taxpayer identity, tax period, assessment number, disputed items, requested amounts, dates, signatures and submission authority.
After using eFiling or the applicable manual route, save the final generated form, the precise uploaded files, the confirmation message, case number and receipt timestamp. A folder marked “final” before those records exist is only a draft package.
Maintain the file after objection
Lock the submitted version and continue work in a new dated folder. Add invalidity notices, SARS requests, objection outcomes and payment-suspension correspondence without overwriting the record of what was originally filed. Appoint one person to monitor eFiling and a second contact for absence cover.
If the objection is disallowed or partly allowed, the appeal must remain connected to the parts and amounts already objected to. A well-indexed source file lets the team compare SARS's outcome reasons with each original ground and decide whether further evidence or legal work is justified.
Important limitation
This evidence-organisation guide does not decide admissibility, relevance, privilege, the burden of proof or whether a document substantiates a particular objection ground.
FAQs
Should I send SARS original source documents with the objection?
Keep originals safely and submit clear copies in the prescribed channel unless SARS specifically requires another form. Record where each original is held and preserve the exact delivered set.
What should a SARS objection exhibit schedule show?
It should link each disputed item and factual proposition to a stable exhibit number, identify whether SARS received it before, and show the reviewer and any unresolved evidence gap.
How do I distinguish new evidence from documents already sent to SARS?
Maintain a delivery ledger with date, channel, case reference and receipt, then mark every exhibit in the objection register as previously delivered, new or replacement.
Should legal advice be stored with the accountant's objection work papers?
Usually separate workspaces are safer. Legal professional privilege is document-specific and does not automatically protect accounting material or ordinary business records.
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Legal note
This article is general legal information for South African readers. It is not legal advice. Speak to a qualified legal professional about your specific facts before taking action.