Case law and the Tax Administration Act provide clear authority that income tax liabilities arise when the ITA34 assessments are issued by SARS, and for VAT and payroll tax liabilities, on the date the relevant payments and returns are due. A previous article discussed the ranking of tax debts and observed that income tax liabilities arise on assessments, unlike VAT and payroll tax liabilities, which arise in the relevant period of supply or payroll period. This article provides the authority behind this view.