Questions over alleged tax evasion, undeclared benefits and criminal investigations linked to Jacob Zuma have resurfaced, reports TimesLIVE.

SARS has complained in court papers that records involving the former President and his ties to Royal Security were inconsistently dealt with in an enforcement notice compelling the tax authority to disclose documents relevant to his tax affairs.

The dispute, now before the Gauteng High Court (Johannesburg) centres on attempts by UK-based financial journalist Warren Thompson to access Zuma’s tax records for 2010 to 2018.

Allegations had been made that Zuma may have received taxable income, fringe benefits, and other financial advantages that were allegedly not fully declared or properly accounted for during his Presidency and thereafter.

Focus was placed on records involving Royal Security, identified in the papers as Zuma’s employer or client during portions of the relevant period.

Papers filed by SARS on 12 May show it is seeking to review and set aside an enforcement notice issued by the Information Regulator in November 2025, which directed the tax authority to release several categories of records linked to Zuma’s finances.

In its founding affidavit by deputy information officer Siyabonga Nkabinde, SARS said the regulator’s order compels it to disclose documents to Thompson, who ‘has sought access to the former President’s tax records for a number of years’.

The papers further show that the Information Regulator sought clarity from SARS on whether Zuma had declared fringe benefits and whether legal action had ever been instituted against him for unpaid taxes between 2010 and 2018.

But SARS now claims the enforcement notice issued by the regulator is contradictory and legally defective.

According to the affidavit, references to criminal investigations involving Zuma and Royal Security appeared in parts of the regulator’s findings but were omitted from the operative sections of the enforcement notice itself, creating uncertainty over whether those records were ultimately meant to be disclosed.

According to TimesLIVE, Thompson first sought access to Zuma’s income tax returns in 2019 in terms of the PAIA. SARS initially refused the request, citing taxpayer confidentiality.

Thompson’s internal appeal was later dismissed before the broader issue of taxpayer secrecy was dealt with by the Constitutional Court in the landmark Arena Holdings matter.

The Constitutional Court ruled taxpayer confidentiality is not absolute and that records may be disclosed in the public interest under section 46 of the PAIA in certain circumstances.

Armed with that judgment, Thompson renewed his request in June 2023, arguing disclosure of Zuma’s records would reveal evidence of substantial contraventions of the law and possible tax noncompliance, but SARS again declined the request.

Thompson lodged complaints with the Information Regulator challenging SARS’ refusal. The regulator later issued an enforcement notice directing SARS to disclose records linked to Zuma’s tax affairs.

However, SARS now claims the notice is riddled with contradictions, including orders to provide records that may not exist or cannot be located.

SARS argues the case raises constitutional questions about the powers of the Information Regulator, the principle of legality and the extent to which taxpayer confidentiality can be lifted in matters involving allegations of public interest tax misconduct.

Full TimesLIVE report