ACCOUNTING & BOOKKEEPING

How should I organise overdue tax returns across several tax types?

Reviewed 7 min read

Quick answer

Create one return register for each legal taxpayer, showing every tax type and period, its official status, missing records, notices and responsible person. Confirm which returns are genuinely required before preparing them. Prioritise urgent notices and deadlines while respecting dependencies between periods and tax calculations. Keep current obligations moving alongside the backlog. Filing, paying debt and resolving penalties are separate tasks, so track each one and retain the official evidence for completed work.

Start with the taxpayer rather than a pile of notices

List the legal entities and individuals involved, with the correct tax references for each registered tax type. A director’s personal return, a company income tax return and the company’s VAT or employer declarations belong to different records. Mixing them in one undifferentiated folder makes it easy to clear the wrong item or overlook an obligation.

Establish authorised access and the correct representative arrangements before relying on a portal view. If a previous accountant controlled access, organise a proper handover of records and permissions. Do not treat missing access as proof that no return exists. Gather official correspondence and prior submission evidence so the starting inventory reflects both the SARS position and the business’s records.

Build a return-by-return inventory

FieldWhat to record
IdentityLegal taxpayer and correct reference
ObligationTax type, return and exact period
Official positionOutstanding, filed or another evidenced status
Evidence availablePrior return, acknowledgement, assessment or account record
Preparation gapMissing books, payroll, invoices or calculations
Notice or deadlineActual correspondence and response date
ResponsibilityPreparer, reviewer and next action owner
Payment positionSeparate liability, payment or dispute status

Use one line for each period instead of writing VAT outstanding as a single task. The number of periods, supporting records and dependencies can differ greatly between tax types. Preserve a dated snapshot of the starting position for later reconciliation.

Confirm what is actually required

An outstanding item may reflect an unfiled required return, an incorrect registration period, a return filed through another channel or a status discrepancy. Investigate the reason before choosing the remedy. Check the current official requirements and the taxpayer’s facts. The business’s statement that it did not trade does not, by itself, establish that no return was required or that every figure should be zero.

Likewise, CIPC deregistration, stopping business activity and cancelling a SARS registration are not interchangeable events. Establish the effective dates and remaining obligations with the appropriate authority and adviser. Do not submit a string of nil returns merely to remove portal warnings when bank interest, assets, liabilities, payroll or other activity may need to be reported.

Recover the records needed for accurate preparation

Collect bank statements, sales and purchase records, payroll reports, asset schedules, prior accounts and existing tax calculations for the relevant periods. Reconcile transactions and identify gaps. An old return cannot be prepared reliably from the current bank balance alone. Where records are missing, request duplicates and document the reconstruction method and limitations.

Keep original evidence and a clear trail of corrections. Do not create invoices or invent dates to make a period appear complete. If the available information cannot support a material figure, ask the adviser how to resolve the issue using the actual facts and applicable process. An unsupported return may create further assessments or disputes rather than solving the backlog.

Choose an order that respects dependencies

Earlier periods can establish opening balances, losses, asset values or other amounts needed for later work. Payroll monthly records feed into employer reconciliations, and VAT records may need to agree with the underlying sales and purchases. Identify those links before assigning a random order based only on which return looks easiest.

At the same time, an urgent official notice or current deadline may require action before the entire historical reconstruction is finished. Record the response date and obtain advice on the appropriate response. Do not assume that working oldest first overrides every notice. The recovery plan should combine chronological dependencies with the actual urgency of each obligation.

Illustrative example: three backlogs share the same records

A fictional company has missing VAT periods, an outstanding employer reconciliation and an overdue annual income tax return. The owner initially asks three people to complete them independently. During review, the team finds that payroll journals are incomplete and some sales invoices were posted twice. Those bookkeeping issues affect more than one return.

The team first agrees a controlled correction of the source records. It reconciles the affected payroll periods and monthly employer declarations before finalising the employer reconciliation. It reviews sales and purchase evidence for the VAT periods and uses the corrected annual accounts for the income tax work. Urgent notices are tracked separately throughout.

This example does not prescribe one universal filing order. It shows why shared records and dependencies should be identified. Each completed return still needs its own review and submission evidence. Correcting the accounting records alone does not file the returns, and filing them does not automatically settle the resulting debt.

Keep current compliance running alongside recovery

Assign someone to maintain current bookkeeping, payroll and upcoming returns while the backlog is being addressed. Otherwise the business can clear old periods while creating new overdue ones. Use a separate current-obligations calendar and reserve time for it. The recovery plan should state who handles routine work and who resolves historical exceptions.

Where the same person performs both roles, set realistic priorities and review progress against actual completed periods. A promise to finish everything soon is less useful than an agreed sequence with records required, review dates and submission evidence. Update the plan when a missing record or official query changes the expected workload.

Track filing, debt and penalties separately

A return can be submitted while an amount remains payable. A payment can be made while the return remains outstanding. Penalties, interest, disputed assessments and payment arrangements may require separate processes and advice. Record each issue with its own reference and status rather than marking the whole tax type complete after one action.

Do not assume that submitting overdue returns automatically cancels penalties or that requesting a payment arrangement suspends every collection or payment obligation. Review the actual SARS notices and applicable procedures. If the business cannot pay, gather current financial information and seek advice promptly about the available options instead of delaying accurate filing solely because the result may be unaffordable.

Verify completion against official records

For each return, retain the filed version, official acknowledgement and relevant assessment or account information. Check any validation failure, supporting-document request or later correspondence. The article on proof of tax return submission explains why a saved draft and a completed filing are different stages.

After a group of periods is completed, compare the return register with the current SARS position and investigate mismatches. Record the date of the check. A tax compliance status result is a separate overview and may reflect several factors; it should not replace the detailed evidence showing which periods were filed and which issues remain open.

Use an exceptions log for difficult periods

Some periods may remain unresolved because a bank archive is missing, a prior submission is disputed or a registration date is incorrect. Record the exact blocker, evidence already obtained, next action and responsible person. Keep these periods visible while independent work continues. Do not mark them complete because they have been handed to another person or because a query reference was issued.

Review the log with the adviser and decide when escalation or a different official process is needed. Preserve correspondence and avoid making inconsistent submissions while a status or assessment question is unresolved. The aim is an accurate, traceable recovery, not merely reducing the number of red indicators on a screen.

Bring a finite recovery scope to your adviser

Vatco’s tax returns submission service can help organise the preparation and filing work. Bring the entity list, tax references, return inventory, notices and available records. Agree which periods are included, what the business must provide and how completion will be evidenced.

For a separate tax debt discussion, the tax debt and payment arrangements service is relevant. Keep that scope distinct from return preparation. A clear recovery register lets the owner see completed filings, payments, queries and unresolved records without mistaking progress in one area for full compliance.

Sources and review

Checked on 30 September 2026. Use the linked official guidance for current requirements and forms.

  1. SARS record keeping

    Official obligations for keeping records, including situations involving unsubmitted returns and ongoing enquiries.

  2. SARS corporate income tax

    Official return, registration and payment context. Historical numeric filing criteria on the overview are not reproduced as current universal thresholds.

  3. SARS employer reconciliations

    Official dependencies between declarations, payments and employee certificates.

  4. SARS tax compliance status

    Official compliance overview context; a status view is not substituted for period-level submission evidence.

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