Diesel refund · Compliance · South Africa

Diesel refund audit: 7 evidence gaps that weaken your position

A diesel refund audit is rarely decided on legal theory alone. SARS tests whether litres, assets, activities and records tell a consistent story. These are the gaps we see most often, and they are fixable if addressed early.

1. Logbooks that do not tie to real assets

Generic or reconstructed logbooks are a red flag. Records should identify specific equipment, sites or activities in a way that can be verified against asset registers, telematics, maintenance records or operational schedules.

2. Litres purchased but not reconciled to use

Many disputes start with a simple question: where did the diesel go? Without reconciliations between purchases, tank levels, dispensing records and consumption, the business cannot prove eligible use, even if it occurred.

3. Weak delivery and receiving documentation

Invoices alone are not enough. Delivery notes, weighbridge slips, tank dip records and receiving controls help prove that diesel entered the operation and was available for eligible use.

4. Asset allocation that changes after the fact

When equipment is reassigned between qualifying and non-qualifying activities without contemporaneous records, SARS will treat the allocation as unreliable. The system must reflect reality at the time of use.

5. Site controls that cannot support the claim

Unmetered dispensing, shared tanks, poor access controls or informal borrowing between sites all create doubt. Practical fuel controls are part of the evidence package, not a separate IT project.

6. Eligible use described in theory, not operation

Position papers that sound correct legally but do not match how work is done on site will fail under scrutiny. The operational narrative and the tax position must be the same story.

7. No single evidence map before submission

Businesses often hold documents in silos: finance, operations, legal. Without an evidence map linking each element of the claim to source proof, submissions become long but unconvincing.

What to do before SARS escalates

Run an evidence test: for each major category of litres claimed, identify the document, system record or control that proves eligible use. If the answer is “we can probably explain it,” you have a gap worth closing now.

Meridian helps mining, industrial and fuel-intensive businesses with diesel refund compliance, audit preparation and practical fuel control improvement before a dispute becomes the only option. For the 2026 platform shift, see SARS new diesel refund platform: what to prepare.

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