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Apply for an Advance Tax Ruling (ATR)
The Advance Tax Ruling System (ATR) is intended to promote clarity, consistency, and certainty in respect of the interpretation and application of the tax laws to which it applies. A Binding Private Ruling (BPR) or a Binding Class Ruling (BCR) allows you to obtain both clarity and certainty on the Commissioner’s interpretation and application of the tax laws on proposed transactions. Provided that you have fully and accurately disclosed the facts in connection with your proposed transaction and actually carry it out as described in your application, the ruling will generally be binding upon the Commissioner when you are assessed on that proposed transaction.
The scope and limits of this binding effect are discussed in further detail in the guides.
In general, prior to the introduction of the ATR System, the Commissioner did not have the authority to issue binding rulings in respect of the application or interpretation of the tax laws. The only exception to this rule concerned certain rulings issued under Section 41 of the VAT Act.
All Binding General Rulings, Binding Private Rulings and Binding Class Rulings will be published in edited form. Prior to publication, applicants will review and approve the draft version of the sanitised (edited) ruling to protect their privacy.
Sanitised (edited) rulings are published on this website as general information and a third party may not rely upon an ATR under any circumstances. In addition, a third party may not cite a BPR or BCR in any proceeding before the Commissioner or the courts.
If you have any questions in connection with the ATR System or would like additional information, contact the ATR Unit or visit the eFiling website. Please note that the contact details below are only available for ATR enquiries. Kindly contact the SARS Contact Centre on 0800 007277 0800 007277 for all other enquiries.
Email: ATRInfo@sars.gov.za
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