Prof SP van Zyl


Position, academic and professional qualifications

SP van Zyl is a Professor in the Department of Mercantile Law, and a research fellow at the African Tax Institute at the University of Pretoria. He holds the degrees LLB, LLM (Pret), LLD (Unisa), as well as a Diploma in Insolvency Law and Practice (AIPSA/UP). The title of his doctoral thesis is “The Collection of Value Added Tax on online Cross-Border Trade in Digital Goods” (2013). He is also an NRF-rated researcher.

Academic and professional experience

Van Zyl is a visiting professor at the Gujarat National Law University, India. He served as an advisor for the Davis Tax Committee. He is a member of the African Tax Administration Forum VAT Technical Committee and he serves on the Scientific Committee of the African Tax Research Network.

Teaching activities

He teaches Income Tax Law, Value Added Tax Law, Tax Administration, and International Tax.

Areas of specialisation

Van Zyl's research primarily includes consumption taxes, tax policy, law and economics.

Recent representative publications (2016 to 2019)

  • The Classification of the Transfer of Intellectual Property Rights under a Franchise Agreement for Purposes of Consumption Tax (VAT): India and South Africa Compared THE COMPARATIVE AND INTERNATIONAL LAW JOURNAL OF SOUTHERN AFRICA (2016) 49(2) p282-304
  • The meaning and application of the zero-rating provisions of sections 11(2)(l) of the Value Added Tax 89 of 1991 ABD CC v The Commissioner for the South African Revenue Service TC-VAT 969 CTN – 30 March 2015 JOURNAL FOR CONTEMPORARY ROMAN DUTCH LAW (2016) 79(4) p504-514
  • The Retrospective Amendments to tax Legislation and the Taxpayer’s right to Property and Economic Freedom JOURNAL FOR SOUTH AFRICAN LAW (2016) nr 3 p563-575.
  • Does the issue of shares by a subsidiary company to a foreign holding company amount to taxable income in the hands of the issuing company? Vodafone India Services Pvt Ltd v Union of India JOURNAL FOR CONTEMPORARY ROMAN DUTCH LAW (2017) 80 (3) p412-433
  • A Cry for Certainty as to the Meaning of ‘Accrued to' for Purposes of Section 1 of the Income Tax Act 58 Of 1962: A Case of M v CSARS (14005) [2017] ZATC 1(30 May 2017) JOURNAL FOR CONTEMPORARY ROMAN DUTCH LAW (forthcoming August 2018)
  • The Time is Ripe to Re-Look the Pay-Now-Argue-Later Principle Vuyisile Zamindlela Nondabula v Commissioner: South African Revenue Service Case no 4062/2016 (EC) 27 June 2017 JOURNAL FOR CONTEMPORARY ROMAN DUTCH LAW (2018) 81 (1) 163
  • Some Drastic Measures to Close a Loophole: The Case of Pienaar Brothers (PTY) LTD v Commissioner for the South African Revenue Service (87760/2014) [2017] ZAGPPHC 231 (29 May 2017) and the Targeted Retroactive Amendment of Section 44 of the Income Tax Act 58 of 1962"PER / PELJ 2018(21)
  • Taxpayer revolt: Withholding taxes due vs SARS’ right of recourse against a defaulting taxpayer 2019 (82) THRHR 1-18
  • The issue of prescription in tax: CSARS v Char-Trade (776/2017) ZASCA 89 (31 May 2018)  THRHR (forthcoming)
  • Chapter 9 (commercial contracts and commercial securities) in Stoop (with the assistance of Masuku, Swart, De Ru, Visser, Stoop, Koekemoer, Van Zyl & De Gama) Commercial and Economic Law South Africa (2019, Kluwer Law International, the Netherlands) (edited by Stuyck & Terryn).

Recent papers (2016 to 2019)


  • African Tax Research Network, Second Annual Congress, Seychelles, 2016
  • The Retrospective Amendments to tax Legislation and the Taxpayer’s right to Property and Economic Freedom
  • African Tax Research Network, Third Annual Congress, Madagascar, 2017
  • Third ATAF International Conference on Tax in Africa, Abuja, Nigeria, 2017
  • South African Revenue Services Thought Leadership Seminar, Pretoria, South Africa, 2017
  • African Tax Research Network, Fourth Annual Congress, Morocco, 2018
  • African Tax Research Network, Fifth Annual Congress, Senegal, 2019

Tel: +27 (0)12 420 4484

E-mail: [email protected]


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[March 2020]

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