Most tax criminal offences are not premeditated acts of tax evasion, but ordinary events that now - in terms of the Tax Administration Act - expose individuals and businesses to the possibility of committing offences that carry harsh penalties, including fines, imprisonment, and other implications for those convicted.
With the requirement that a tax criminal offence is committed “wilfully” now removed, even inadvertent or administrative errors can be penalised to the maximum, which is why SARS itself says that professional tax assistance is crucial to avoid these tax criminal offences.