Maumela’s family trust fights R1.9 billion SARS bill in High Court
The South African Revenue Service has assessed the MHR Family Trust, whose trustees are alleged Tembisa Hospital syndicate head Hangwani Morgan Maumela, his mother and his sister, for R1 929 830 817 in tax, penalties and interest. The trustees went to the High Court in Pretoria on 17 September 2026 to have the assessments reviewed and set aside, arguing that SARS raised them while settlement talks were still running. SARS says the trustees gave it almost nothing during the audit and that the trust claimed more than R1.17 billion in deductions it cannot account for. Judgment on the first part of the application has been reserved.
What SARS says it found
SARS flagged the trust’s returns for verification in 2022. In December 2023 it obtained a preservation order over the trust and a curator was appointed. That order was discharged on 2 August 2024 in terms agreed by both sides, which recorded that the trust would cooperate with the audit, that the audit would be concluded within 60 days, that a further 60 days would be available to settle the matter, and that major assets could not be dissipated in the meantime.
For the 2018 to 2022 tax years the trust claimed R1 174 049 818 in deductions. SARS disallowed R1 173 999 930 of it. The only expense it accepted was R49 887.19 in bank charges.
In its letter of findings SARS said the disallowed amounts consisted mainly of round amounts paid to unidentified individuals and to companies linked to Maumela, together with substantial payments for luxury vehicles and properties in high end suburbs in the Western Cape, Gauteng and Durban. It said it found no evidence that any of that spending was incurred to produce the trust’s income. Payments described as salaries were also identified, but SARS said the trust was not registered for employee tax and that the recipients could not be identified.
The assessment of 13 August 2024 put the total at R1 929 830 817, including tax, penalties and interest. SARS described the trust’s conduct as intentional tax evasion and said its failure to produce records was obstructive. A letter of demand followed 2 days later.
What the trustees say
Maumela says the trust’s attorneys and accountant met SARS in May 2024 and made it clear that the annual financial statements previously submitted had not been properly prepared, through no fault of the trust. A new accountant had been appointed and had found that certain expenditure and revenue items had not been correctly accounted for, which the trustees say would significantly reduce the liability once fixed.
The trustees say they also disclosed intercompany loan transactions between the trust and related entities and were preparing a loan matrix to explain the flow of funds. Corrected statements were eventually submitted, they say, and SARS neither properly considered them nor conducted a proper audit.
SARS disputes this. Sandy Tsumaki, its senior manager in the division dealing with syndicated tax and customs crime, said attempts to engage the trustees were futile, only a handful of documents were provided, and nothing was submitted during the audit itself. He said the loans could not be accepted because no loan agreements or ledgers were produced and the statements were unsigned and prepared on a going concern basis when the trust has been technically insolvent since its inception. Roughly R1 billion in loans was claimed against declared income of about R13 million.
The contempt application and the 11 days
Running alongside the review is a contempt application, in which the trustees say SARS breached the order of 2 August 2024 by assessing them 11 days later, on 13 August, before the agreed settlement period had run.
The timeline complicates that argument in one respect. SARS issued its notification of audit in May 2024 and its letter of findings in early July 2024, both before the order was signed, so the audit work was largely complete by 2 August. The settlement period is the harder part for SARS to defend, since a window agreed for talks achieves little if an assessment is issued on day 11.
Which court hears it
The proceedings on 17 September 2026 did not reach the merits. They dealt only with Part A, on whether the High Court has jurisdiction or whether the matter belongs in the Tax Court. Judgment was reserved.
The distinction is more than procedural. An appeal in the Tax Court argues whether the amounts were properly claimed. A review in the High Court argues whether SARS followed its own agreement and its own rules in raising the assessments. A successful review sets the assessments aside without any finding on where the money went, although SARS would be able to rework the audit and assess again.
The wider picture
SARS is not the only arm of the state acting on the Maumela network. On 20 July 2026 the High Court in Johannesburg granted a final forfeiture order over assets worth about R326 million, and in August 2026 SARS raised R39.9 million in assessments against Mboneni Maumela, which she is also challenging. The SIU’s interim report of September 2025 identified the Maumela syndicate as the largest of 3 coordinated syndicates at Tembisa Hospital, with 1 728 bundles worth R816 560 710 under review and at least 41 suppliers tied to it.
Hangwani Maumela has not been criminally charged. Appearing before Parliament’s Standing Committee on Public Accounts on 18 August 2026, National Director of Public Prosecutions Andy Mothibi said the Hawks are leading the investigation and that it remains active. Mothibi told the committee the NPA is dealing with the matter decisively and leaving no stone unturned.
Babita Deokaran flagged 217 companies and halted more than R100 million in payments before she was murdered outside her home in 2021. 6 men have been sentenced for her killing. Nobody has been identified as the person who paid them.
Maumela is the President’s nephew from a previous marriage. Cyril Ramaphosa has said he does not know him. Maumela denies wrongdoing and no court has found against him.
