Sandton: Senior Tax Attorney (Tax Disputes & Tax Debt) posted by Pro Tem

Location: Rosebank, Johannesburg (In-Office, Full-Time)

Team: Tax Legal

Reports to: Executive / Head of Tax Legal

Read This Before You Apply

This is not a training role.

This is not a step up when ready position.

You will be expected to run complex SARS disputes and tax debt matters independently, make judgment calls, manage risk, and guide junior attorneys, with executive-level oversight, not supervision.

If you are looking to still learn how tax disputes work, this is not the role.

If you are uncomfortable being accountable for outcomes, deadlines, and quality, this is not the role.

Who We Are Looking For

We are looking for a senior tax attorney who:

Thinks clearly under pressure and does not escalate unnecessarily

Is technically strong and comfortable standing behind their work

Can manage complex, high-value and high-risk SARS matters end to end

Understands that tax disputes are both legal and strategic

Is comfortable mentoring juniors while still carrying their own load

Wants to build something long-term, not simply hold a senior title

If you expect heavy structure, rigid hierarchies, or minimal responsibility, you will not enjoy this environment.

My client is a specialist tax, legal and advisory firm serving entrepreneurs, growing businesses, and high net worth individuals across South Africa and the continent.

Our core focus areas include:

SARS disputes and tax debt management

Tax administration and compliance

Corporate and commercial advisory

Accounting and financial reporting

We operate in a high-performance, delivery-driven environment. Structures are actively being built and refined. Senior team members are expected to contribute to both technical outcomes and process maturity.

We are actively building a diverse tax legal team and welcome applications from candidates of all backgrounds who meet the requirements.

The Role

You will join the firm as a Senior Tax Attorney within the tax legal team, taking responsibility for the management, strategy and execution of tax dispute and tax debt matters.

You will:

Run complex SARS disputes and tax debt matters independently

Act as a technical and strategic resource within the team

Supervise and guide junior attorneys on active matters

Engage directly with SARS, clients, counsel and executives

Contribute to the development of internal systems, standards and templates

This role has clear progression into leadership, depending on performance and appetite.

Key Responsibilities

1. SARS Disputes & Litigation (Core Function)

• Lead disputes across tax types (Income Tax, VAT, PAYE, penalties, understatement penalties)
• Draft and review:
• Requests for reasons
• Objections and appeals
• ADR requests and settlement proposals
• Legal submissions and representations
• Strategise dispute positioning, evidence and escalation risk
• Prepare and manage dispute chronologies, bundles and legal arguments
• Brief and liaise with counsel where matters escalate to formal litigation

2. Tax Debt Management & SARS Engagement

Lead:

• Suspension of payment applications
• Deferred payment arrangements
• Compromise / write-off applications
• Draft high-quality representations for remission of penalties and interest
• Engage with SARS collections and legal divisions strategically, not reactively
• Manage prescription risk, payment exposure and enforcement timelines

3. Technical Oversight & Research

• Interpret and apply the Tax Administration Act, Income Tax Act and VAT Act in live matters
• Review and refine junior attorneys research and drafting
• Draft internal opinions and technical guidance notes
• Stay current on case law, SARS interpretation notes and administrative developments

4. Team Leadership & Quality Control

• Supervise junior attorneys on disputes and tax debt files
• Review key documents before submission to SARS or clients
• Ensure consistency of approach, tone and technical accuracy
• Contribute to the development of templates, checklists and internal processes

5. Client & Internal Stakeholder Management

• Act as the primary legal contact on allocated matters
• Participate in and lead client calls and meetings
• Communicate risks, strategy and progress clearly and commercially
• Escalate issues appropriately, with solutions proposed

Minimum Requirements (Non-Negotiable)

If you do not meet these, please do not apply.

Education & Admission

• Admitted Attorney of the High Court of South Africa
• LLM in Taxation (completed)

Experience

• Minimum 5 years post-admission experience, with substantial exposure to:
• Tax disputes and/or tax debt management, or
• High-level litigation or administrative law with strong tax exposure
• Proven experience running matters independently from instruction to resolution
• Demonstrated experience drafting complex legal submissions (not merely correspondence)

Technical & Professional Skills

• Strong command of tax administration law and dispute procedures
• Excellent legal drafting and structured written English
• High attention to detail and accuracy
• Confident working directly with SARS and counselStrong organisational skills and deadline discipline

Way of Working

• Calm, level-headed and solutions-driven
• Comfortable taking ownership and accountability
• Professional, direct and constructive in communication
• Able to mentor juniors without slowing down delivery

Preferred (Strong Advantages)

• Experience dealing directly with SARS dispute resolution and collections units
• Experience in high-value or complex tax matters
• Experience supervising or mentoring junior attorneys
• Fluency in English and Afrikaans (additional South African languages are an advantage)

Who This Role Will Suit

This role is ideal if you:

Want to be technically strong and operationally trusted

Enjoy complex files, regulatory pressure and strategic problem-solving

Want influence over how a tax legal practice is built and run

Value quality and credibility over prestige branding

You will struggle in this role if you:

Avoid accountability for outcomes

Need constant direction or validation

Are uncomfortable making judgment calls under pressure