The question of “Selective Prosecution” has been asked since 2007 when the South African Revenue Service (“SARS”) started using Lifestyle Audits on private individuals. The selection basis, was the means of the individual, in contrast to their standard of living, and was conducted on individuals where there was a suspicion of criminal activity. With the introduction of the High-Net Worth Unit, Edward Kieswetter, commissioner of SARS, noted in the National Tax Indaba of September 2021, that SARS’ position is to focus on collecting the “lowest hanging fruit”, which has been clarified by SARS’ actions over the following months.