Foreign tax recovery assistance
Section 185 of the Tax Administration Act, 2011, makes provision for the recovery of tax on behalf of foreign governments.
Requests for assistance in recovery of tax are made –
by the South African Competent Authority (SARS) to the Competent Authority of the relevant tax treaty partner with whom South Africa has a double taxation treaty or agreement in place; or
by the Competent Authority of the relevant foreign tax treaty partner with whom South Africa has a double taxation treaty or agreement in place
Requests can therefore only be made the Competent Authority of a Foreign Tax Treaty Partner and not by members of the public (taxpayers).