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Regularisation for Individuals and Trusts: VDP vs SVDP

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Taxpayers and their tax advisors now have the opportunity to regularise tax and exchange control offenses committed in the past by making use of the Special Voluntary Disclosure Programme (SVDP) that is now in effect.

This course will cover the regularisation options available for individuals and trusts with particular reference to the VDP and the SVDP.

The objective of the course is to prepare tax professionals so that they can assist clients in determining the best route for regularisation.

    Course Content

  • A short history on regularisation in South Africa
  • Income tax regularisation – the legal framework (VDP and SVDP)
  • Comparing the VDP and SVDP – requirements for eligibility
  • The income tax regularisation process, timelines, etc.
  • Exchange control regularisation – the legal framework (SVDP and other)
  • Comparison of the SVDP and the regularisation outside of the SVDP
  • Supporting documents


Melissa Duffy

Melissa joined KPMG in October 2004. She is currently a partner in the global mobility services and employment tax advisory unit at KPMG. She is one of the leading tax experts who advises clients on the SVDP and VDP, assisting them with their tax compliance. She is also a senior member of the income tax and exchange control regularisation team. Melissa has travelled to Zurich to meet with the Swiss banks to create awareness about the SVDP.

She is a registered master tax practitioner with the South African Institute of Tax Professionals (SAIT) and has over 15 years of experience in taxation. In addition to her specialisation in South African voluntary disclosure, she has a keen focus on individuals, expatriate employees and the so-called high net worth individuals. She also provides global mobility advisory services - in other words, she assists organisations in meeting their employees’ global human resources needs.

Melissa has a number of publications on the hot topic of voluntary disclosure in South Africa. These publications not only include her KPMG publications that specifically address the South African VDP but also articles published by the SAIT, most recently the TaxTalk January/February 2017 edition’s article “Declare now or forever hold your pieces”.




Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.

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