Absa Bank Limited and its wholly owned subsidiary United Towers Proprietary Limited entered into an investment arrangement involving a series of interlinked transactions. They subscribed for preference shares in PSIC3, which used the proceeds to invest in PSIC4, which made a capital contribution to D1 Trust. D1 Trust made interest-bearing loans to Macquarie Securities South Africa Ltd and invested the interest earned in Brazilian Government Bonds, which under the Double Taxation Agreement provided a tax-free income stream. This income flowed back to Absa and United Towers as dividends. SARS initiated an investigation in 2016 and issued audit notices in May 2018. On 30 November 2018, SARS issued notices under s 80J of the Income Tax Act indicating its intention to apply the General Anti-Avoidance Rule (GAAR) provisions. On 15 February 2019, Absa and United Towers requested withdrawal of these notices under s 9 of the Tax Administration Act (TAA). SARS refused on 5 March 2019. On 29 March 2019, Absa and United Towers launched a review application seeking to set aside the refusal to withdraw the s 80J notices. On 17 October 2019, SARS issued additional assessments for the 2014-2017 tax years, determining that the investment returns constituted taxable income. Absa and United Towers amended their application to include a review of these assessments.