Tribunal rules for ITQNET in E8.8m tax dispute
Eswatini Revenue Service failed to respond to ITQNET's objection within a reasonable period.
The Revenue Appeals Tribunal Eswatini ruled in favour of ITQNET Investments (Pty) Ltd in a tax dispute over E8 844 147.70. The tribunal found the Eswatini Revenue Service (ERS) did not respond to ITQNET's objection within a reasonable time. The ruling on October 8, 2026, stated ITQNET's objection was allowed by operation of law after ERS took about 10 months to decide.
The dispute began after an ERS audit disallowed expenses ITQNET claimed as deductions. This led to a revised assessment of E8 844 147.70 in additional tax and penalties. ITQNET, an IT services provider to the Eswatini government, argued the expenses were incurred to produce income. The company lodged its objection with ERS on April 16, 2025.
ERS issued its decision on February 19, 2026, which ITQNET challenged. The company argued ERS failed to act within the legally required reasonable period. The tribunal also examined ERS's 'pay now, argue later' principle, stating it does not override ERS's obligation to determine objections.
Why it mattersITQNET Investments (Pty) Ltd, a company providing information technology services to the Eswatini government, won a tax dispute of E8 844 147.70.