Section 180 (TAA) – Liability of financial management for tax debts

180.    Liability of financial management for tax debts

 

A person is personally liable for any outstanding tax debt of the taxpayer to the extent that the person’s negligence or fraud resulted in the failure to pay the tax debt if-

 

(a)     the person controls or is regularly involved in the management of the overall financial affairs of a taxpayer; and

 

(b)     a senior SARS official is satisfied that the person is or was negligent or fraudulent in respect of the payment of the tax debts of the taxpayer.