Sars’s Voluntary Disclosure Programme (VDP)

The onus is on the applicant to establish on a preponderance of probabilities that its VD Application had been brought voluntarily o be successful. If an  an element of compulsion was present at the time the taxpayer sought VDP relief it will indicate an absence of volition by the taxpayer. For more details see Purveyors South Africa Mine Services (Pty) Ltd v Commissioner for the South African Revenue Service