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

About the Role

We are seeking a senior tax attorney to join our tax legal team in Rosebank, Johannesburg. As a key member of our team, you will be responsible for managing complex SARS disputes and tax debt matters independently, making judgment calls, managing risk, and guiding junior attorneys with executive-level oversight.

Key Responsibilities

• 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

• 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

• 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

• 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

• 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)

• Education & Admission
• Admitted Attorney of the High Court of South Africa
• LLB 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 counsel
• Strong 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
• 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