Fuel, Tax, and Billions: Astron Energy’s R2.7 Billion Showdown with SARS Heads to Court

Petrol giant Astron Energy is challenging a massive tax bill from SARS and the court’s decision could ripple through the fuel industry

One of South Africa’s largest petrol station operators, Astron Energy, is locked in a legal battle that could define corporate tax disputes for years to come. At the centre of the storm is a R2.7 billion assessment from the South African Revenue Service (SARS) a figure Astron says is both legally and factually wrong.

The saga dates back to a customs and excise audit SARS conducted between 2015 and 2017, before Glencore acquired the energy group’s Southern African assets. In October 2019, SARS issued a formal demand letter for exactly R2,714,001,723.73, citing unpaid excise duties, fuel levies, penalties, and interest.

But Astron isn’t taking the blow lying down.

Astron Fights Back in Court

The company believes the massive bill is based on flawed reasoning and a misapplication of tax law. In response, Astron has approached the Western Cape High Court, arguing not just for a reversal of SARS’ decision but also for a broader judicial review under the Promotion of Administrative Justice Act (PAJA).

The crux of Astron’s argument? That SARS ignored legitimate refund claims that could have offset the alleged debt. By refusing those claims, Astron says, the tax authority denied the company a fair shot at settling its dues in good faith.

SARS Tried to Shut the Case Down Early

Rather than immediately defending its tax decision, SARS filed “exceptions” — a legal attempt to get large parts of Astron’s application dismissed before trial. The revenue service argued that Astron’s legal filing was confusing, improperly sequenced, and lacked enough detail.

But Judge Moosa wasn’t convinced.

He ruled that SARS hadn’t proven any real harm from Astron’s legal structure and that their objections were more about stalling than substance.

“The exceptions are designed purely as a delaying tactic,” said Moosa, adding that SARS had sat on its hands for over two years before Astron brought the case to court.

Full Trial Ahead And the Stakes Are Massive

With SARS’ objections dismissed, the court gave full permission for Astron’s case to proceed. That means a trial will now examine key questions like:

• Were Astron’s refund claims valid?

• Did SARS’ internal appeal decision constitute a lawful “determination”?

• Does Astron actually owe the R2.7 billion, or should SARS pay money back?

The trial’s outcome could have major implications for how customs duties, fuel levies, and administrative fairness are handled in future tax disputes.

Fueling Up for Growth While Fighting SARS

Astron’s legal woes come at a time when the company is aggressively expanding its footprint. After Glencore acquired Chevron’s local assets in 2017, Astron began operating under the Caltex brand, before announcing a full rebrand in 2021.

By 2025, Astron has successfully rebranded 400 of its 850 service stations, reaching the halfway mark in its mission to become South Africa’s most recognised fuel brand.

CEO Thabiet Booley has been vocal about the company’s ambition to become “the next biggest fuel brand” in the country. But a tax bill nearing R3 billion could become a major speed bump on that road or, if the court sides with Astron, a vindication that clears the path for even faster growth.

Public Reaction: A Battle of Titans

While the court documents may be dry, the public mood is anything but. On social media, South Africans are divided. Some view SARS’ demand as a sign that “no one is above the law,” while others see Astron’s detailed legal pushback as a potential exposure of overreach by the tax authority.

“R2.7 billion is no small change SARS better be sure it’s owed,” wrote one user on X.

“Why did it take them four years to act after issuing the letter of demand?” asked another.

Judge Moosa’s ruling means both the appeal and the PAJA review will be heard. He also ordered SARS to pay costs, including fees for two senior advocates, signaling the court’s frustration with how the tax authority tried to block the process.

The next chapter will play out in full trial, where a single judgement could shift billions, not just for Astron, but for future companies caught in similar SARS disputes.

And for the average South African keeping an eye on the fuel pump and the taxman? This case might just decide who really owes whom and how much.

{Source: BusinessTech}

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