The High Court has dismissed with costs a bid by China Railway Rolling Stock Corporation (CRRC) to appeal an earlier judgment allowing the South African Revenue Service (SARS) to freeze its accounts over about R4 billion in allegedly unpaid taxes.
CRRC had argued it did not receive a final letter of demand. SARS, in turn, argued it was dealing with "a delinquent taxpayer who had sought to defraud organs of state as part of the so-called State Capture, related to Transnet," the judgment read. This meant any funds were potentially at risk, with SARS also arguing that even if the third-party notices were set aside, they would just be reissued after a letter of final demand.