47G.    Personal liability of resident

(1)     A resident who –

(a)     fails to deduct or withhold an amount of tax in terms of section 47D from any payment made to a taxpayer: or

(b)     deducts or withholds an amount of tax but fails to pay that amount over in terms of section 47E,

is personally liable for payment of that amount of tax in accordance with Part A of Chapter 10 of the Tax Administration Act.

(2)     ……….

(3)     Subsection (1)(a) does not apply where the taxpayer has in terms of section 47C(1) paid to the Commissioner the amount of tax payable under this Part in respect of the payment from which the resident has so failed to deduct or withhold the tax.

47H.  . . . . . .

47I.   . . . . . .

[Wording of section 47I prior to amendment by Act 28 of 2011 applicable to the extent it relates to interest]