Medtronic International Trading S.A.R.L, a Swiss company and registered VAT vendor in South Africa, was defrauded by its accountant Ms Steenkamp, who embezzled over R537 million from June 2004 to May 2017. Ms Steenkamp submitted false VAT returns to SARS seeking reimbursements to conceal her embezzlement. After her arrest on 13 December 2017, Medtronic International applied to SARS for relief under the Voluntary Disclosure Programme (VDP) pursuant to sections 225-233 of the Tax Administration Act 28 of 2011 (TAA). During negotiations in March 2018, Medtronic International requested waiver of interest payable on the default, but SARS advised it was not empowered to waive interest under the VDP. Medtronic International elected to proceed and on 18 June 2018 the parties concluded a Voluntary Disclosure Agreement (VDA) whereby Medtronic International agreed to pay capital VAT of R286,464,756.62 plus interest of R171,205,356.12, totaling R457,670,112.74. In exchange, SARS granted 100% relief from administrative non-compliance penalties and understatement penalties, and undertook not to pursue criminal prosecution. Medtronic International fully complied with the VDA and paid the post-relief amount in full. On 12 October 2018, Medtronic International's attorneys requested SARS to remit the interest pursuant to section 39(7) of the Value Added Tax Act 89 of 1991 (VAT Act) and SARS Interpretation Note 61. SARS refused, stating that remission of interest was not catered for in the VDP programme and that sections 39(7) of the VAT Act and 187(6) of the TAA did not apply to VDP agreements.