Advance Tax Rulings (ATR)

The Advance Tax Ruling (ATR) system seeks to promote clarity, consistency and certainty on the interpretation and application of the applicable tax laws.
Clarity and certainty on the Commissioner’s interpretation and application of the tax laws regarding proposed transactions can be obtained by way of a binding private ruling (BPR) or a binding class ruling (BCR).

How to apply

The application process starts with the submission of an application and accompanying documents on eFiling.

The applications must be filed online on the ATR section on The ATR section can be accessed on eFiling after logging in and selecting ‘Services’ and then ‘Other Services’.

The Comprehensive Guide on Advance Tax Rulings contains specific instructions regarding the format in which the application should be submitted.

Application documents must also be uploaded on eFiling when submitting the application.

What you need to know about the ATR system
InformationDocuments and/or links

To apply for an advance tax ruling –

The application for an ATR also involves the payment of fees, which, with other matters, are explained further in the Comprehensive Guide.
A BPR and BCR will be issued at the end of the ATR process. These rulings are sanitised or edited before being added to the SARS website to ensure a client’s anonymity.
Public Notices

The Commissioner may, under sections 80(2) and 81(1) of the Tax Administration Act, 2011, determine the additional considerations in terms of which an application for BPRs and BCRs may be rejected, as well as the application and cost-recovery fees therefor, issued under the ATR system.

Application fees
Applicant CategoryApplication Fee
Small, medium and micro enterprises (SMMEs)R2 500
Any other taxpayerR14 000
Cost-recovery fees
CategoryEstimated fee rangeEstimation deposit
(20% of higher amount)
Hourly rate
StandardR10 000 to R35 000R7 000R650
InvolvedR35 000 to R70 000R14 000R650
ComplexR70 000 to R105 000R21 000R650
Urgent applicationsCase-by-caseCase-by-caseR1 000
In addition to the above, any direct costs incurred in connection with an application will be recovered. These will, however, be subject to prior written approval being obtained from the applicant.

How to apply for VAT Rulings

Applications for VAT BCRs and VAT BPRs as provided for in section 41B of the Value-Added Tax Act, 1991. 
Applications must be submitted to SARS by e-mail to [email protected].
The application should be marked with either “Application for a VAT Class Ruling” or “Application for a VAT Ruling”.
Provided full and accurate disclosure of facts in connection with any transaction has been made and that the transaction is actually carried out as described in the application, a ruling will be binding on the Commissioner.
Top Tip for VAT Rulings:
Applications for VAT rulings are not submitted via eFiling and there are no costs involved – see the VAT Rulings Process Reference Guide under Legal Counsel Publications –> Find a Guide –> Value Added Tax (VAT).

How to apply for decisions under section 72 of the VAT Act, 1991

Applications for decisions under section 72 must be lodged via the ATR eFiling system. These decisions are only considered under very exceptional circumstances and subject to the requirements set out in the said section. The requirements and conditions relating the application for a decision under section 72 are set out in Binding General Ruling 56: Application for a Decision under Section 72. 
Top Tip for applications under section 72 of the VAT Act, 1991:
Applications for decisions under section 72 of the VAT Act must be submitted via eFiling, and is subject to an application fee. See the VAT Section 72 Decision Process Reference Guide  under Legal Counsel Publications –> Find a Guide –> Value Added Tax (VAT).

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