Challenges that the commissioner for the South African Revenue Service’s information gathering powers pose to taxpayers’ rights
Why this work is in the frame
A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.
Bibliographic record
Abstract
This study is about the importance of the duty of the South African Revenue Service (“SARS”) to recognise and protect taxpayers’ rights. Particular focus is placed on the challenges posed with respect to taxpayers’ rights when the Commissioner for SARS (“the Commissioner”) exercises his information gathering powers. This study covers the manner in which the gathering of information by SARS is conducted domestically and internationally and the purposes for which SARS uses that gathered information. \nThe term “information gathering” is not defined in the Income Tax Act 58 of 1962 (“ITA”) or the Tax Administration Act 28 of 2011 (“TAA”). It may, however, be understood to mean the way in which the Commissioner gathers or collects information from taxpayers. The purpose of this information gathering may be for the Commissioner to measure taxpayers’ compliance with their obligation to pay tax. \nThe Commissioner may use the following ways or methods to gather information from taxpayers: records and books, tax returns, request for information from taxpayers or third parties, inspection, verification or audit, search and seizure, exchange of information with other countries, Country-by-Country Reporting, the Voluntary Disclosure Programme and the Reportable Arrangements provisions. \nThe study discusses how taxpayer’s constitutional rights may be infringed when the Commissioner uses these various methods to gather information from taxpayers. The study also discusses the effectiveness of the remedies or avenues available to the taxpayers whose rights have been infringed. \nThe study entails a comparative study of the United Kingdom (“UK”) and Canada, and compares the relevant positions in these two countries on the above matters with the position in South Africa. The aim of this comparison is to develop recommendations for solving the challenges identified in South Africa.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.000 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.002 | 0.000 |
| Scholarly communication | 0.000 | 0.000 |
| Open science | 0.001 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it