The 'pay now argue later' principle in South African Tax Law: its development, operation, comparison to South African civil debt enforcement and consistency with the constitutional right of access to courts

Section 164 of the Tax Administration Act 28 of 2011 (the TAA), previously contained in section 88 of the Income Tax Act 58 of 1962 (the Income Tax Act) and section 36 of the Value-Added Tax (VAT) Act 89 of 1991 (the VAT Act), provides that the payment of tax will not be automatically suspended unti...

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