Published Rulings

Binding General Rulings (BGR), Binding Private Rulings (BPR) and Binding Class Rulings (BCR) 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. If a sanitised ruling compromises the identity of an applicant, it will not be published according to S76O(5) of the Act. If an identical ruling has already been published in sanitised form, it will also not be published as it is considered a duplication.

Sanitised (edited) rulings are published 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.

Note:

Please note that the time period between the dates mentioned in the content of the published ruling and the date the published ruling is made available on the website are not an indication of the timelines involved in issuing a final binding ruling to an applicant.

Once the final binding ruling has been issued to an applicant, it is sanitised (edited) through various internal processes to ensure that the tax treatment of a specific transaction is discussed in sufficient detail to provide guidance for readers thereof while simultaneously ensuring that the applicant's identity is not compromised in any way.

Binding rulings are issued to applicants within the following time periods (excluding days that ATR awaits feedback or information from the applicant):

Category	Estimated fee	Hourly rate	Estimated business days to complete
Standard	R5 000 – R25 000	R400	20
Involved	R25 000 – R50 000	R450	45
Complex	R50 000 – R75 000	R500	60
Extraordinary	Case-by-case	R500	Case-by-case

1. Binding General Rulings

A Binding General Ruling is an advance tax ruling that is issued by the Commissioner, in his or her discretion, in respect of the application or interpretation of a provision of the tax law on matters of general interest or importance

• VAT
• IT - Interpretation Notes

2. Binding Private Rulings

• Published Rulings

A Binding Private Ruling is an advance tax ruling, issued in response to an application, that states how the Commissioner would interpret and apply provisions of the tax laws to a specific proposed transaction

3. Binding Class Rulings

• Published Rulings 

A Binding Class Ruling is an advance tax ruling, issued in response to an application from a class of taxpayers, that states how the Commissioner would interpret and apply provisions of the tax laws to a specific proposed transaction

4. Reconfirmation requests

A reconfirmation request will apply when the date of a ruling which has previously been issued in response to an application has expired.  The reconfirmation request will follow the same timeline as for new applications and must be submitted at least 30 business days prior to the expiry date of the existing ruling issued.  A late reconfirmation request will not be accepted if the request if filed more than 60 business days after the expiry of the issued ruling.

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