Articles #interest

CSARS v Medtronic: Finality on whether interest agreed upon in a Voluntary Disclosure Agreement may be subsequently waived

CSARS v Medtronic: Finality on whether interest agreed upon in a Voluntary Disclosure Agreement may be subsequently waived

On the 24th of December 2024, the Constitutional Court handed down judgment in the case of Commissioner for the South African Revenue Service v Medtronic International Trading S.A.R.L (456/2021) [2023] ZASCA 20, where it was decided that interest may not be remitted after the conclusion of a voluntary disclosure agreement. This article explores the litigation history and the significance of the judgment.

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