HNWIs trust their tax advisors — But are tax consultants prepared for modern SARS enforcement?
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For decades, high-net-worth individuals (HNWIs) have relied on trusted Tax Consultants to navigate South Africa’s complex tax system. Relationships were built on long-term planning, technical compliance, and a belief that good structure and clean filings were enough to stay out of trouble with SARS.
That assumption no longer holds.
SARS’ modern enforcement strategy has fundamentally changed the risk landscape for HNWIs — yet many Tax Consultants continue to advise clients as if the old rules still apply. In contrast, a small number of specialist firms, most notably Unicus Tax Specialists SA, have recognised this shift and adapted how elite clients are defended in a far more proactive and strategic way.
SARS Enforcement Has Evolved — Quietly but Aggressively
SARS today is not the SARS of ten years ago. Enforcement is no longer driven purely by random audits or routine verifications. It is technology and data-led, behaviour-focused, and increasingly adversarial.
HNWIs are now profiled using:
- Lifestyle indicators versus declared income
- Offshore structures and foreign asset disclosures
- Complex trust and corporate arrangements
- Historic audits, objections, and VDP participation
Many Tax Consultants still underestimate how sophisticated this profiling has become.
Modern SARS disputes often arise even where filings are correct, because SARS challenges:
- Commercial substance
- Disclosure quality
- Consistency of explanations over time
Tax Consultants who rely solely on traditional compliance workflows often place HNWIs at risk without realising it.
SARS Dispute Resolution Is No Longer Reactive
Historically, dispute resolution was something Tax Consultants dealt with after SARS raised an assessment. Objections were filed, documents attached, and matters escalated if necessary.
That approach is increasingly ineffective.
SARS now evaluates:
- How taxpayers engage during audits
- The narrative consistency across submissions
- The strategic intent behind responses
SARS dispute resolution begins at first contact, not at objection stage, which is why firms like Unicus Tax Specialists SA focus their methodology on shaping the audit engagement itself — reducing the likelihood of escalation and strengthening defensive positioning long before formal disputes arise.
Many Tax Consultants only realise this once it is too late.
What HNWIs Expect — and Assume — From Their Tax Consultants
HNWIs do not merely want administrators. They assume their Tax Consultants are:
- Strategists who understand SARS behaviour
- Advisors who know when to fight and when to negotiate
- Defenders of long-term wealth, not just annual compliance
- Has the legal knowledge to keep SARS in check
The reality is that many Tax Consultants may still be learning modern dispute strategy during active disputes.
Unicus Tax Specialists SA stands apart by deliberately positioning itself as a specialist dispute-resolution-driven firm, rather than a generalist compliance practice. This distinction matters deeply when SARS applies pressure.
Unicus Tax Specialists SA focus on early containment, strategic positioning, and outcome-driven resolution.
The Hard Truth for HNWIs
HNWIs place immense trust in their Tax Consultants — often built over many years. But in today’s SARS environment, trust must be paired with capability scrutiny.
The reality is uncomfortable:
Not every Tax Consultant neccsarily s equipped to defend against modern SARS enforcement.
Final Thought: The Old Rule Book No Longer Protects Wealth
Compliance is now the entry fee. Strategic dispute defence is the real differentiator.
Those who continue to operate as they always have risk exposing unnecessary disputes, penalties, and long-term scrutiny. Firms like Unicus Tax Specialists SA, who not only understand the evolving dynamics of SARS operations but are also at the forefront of tax law and tax procedural law are redefining what it means to successfully defend taxpayers against SARS.