Company provisional tax overpayment

[taxlibrary]

Apologies, I was thinking of overpayments that are in dispute:
The Income Tax and VAT Acts do not require SARS to pay interest on the overpayment of tax when a taxpayer is required to pay a disputed amount while the amount is subject to objection – with the objection subsequently being allowed. This non-payment of interest is arguably contrary to one of the core principles on which the constitutionality of the “pay now argue later” principle is based. In order to address these concerns, it is proposed that the Income Tax and VAT Acts be amended to:
(i) clarify that payment is not
suspended due to objection,
(ii) formalise the circumstances where payment will
be required despite objection, and
(iii) provide for interest where a payment made
pending consideration of an objection is refunded.