The Commissioner publishes binding rulings when considered necessary, for different reasons and in different circumstances. These rulings are divided as follows:
- Binding General Rulings (BGRs)
BGRs are issued in respect of matters of general importance.
They provide clarity on the application of tax laws in these general matters and can be applied across board.
- BGR 61–80
- BGR 41–60
- BGR 21–40
- BGR 1–20
- Register of all Binding General Rulings (The register comprises an overview of all Binding General Rulings, followed by Binding General Rulings organised according to tax types.)
- Binding Class Rulings (BCRs)
BCRs are issued on application only in favour of a specified class of taxpayers.
They determine how SARS interpret and apply the relevant tax law’s provisions in relation to a proposed transaction.
A binding class ruling is published by consent of the applicant to which it has been issued. It has a binding effect between SARS and the applicant and class members only, and is published for general information. It does not constitute a practice prevailing. A third party may not rely upon a binding ruling under any circumstances. In addition, published rulings may not be cited in any dispute with SARS, other than a dispute involving the applicant or any co-applicant(s) identified therein.
- BCR 81–100
- BCR 61–80
- BCR 41–60
- BCR 21–40
- BCR 1–20
- Register of all Binding Class Rulings (The register comprises an overview of all Binding Class Rulings, followed by Binding Class Rulings organised according to tax types.)
- Binding Private Rulings (BPRs)
BPRs are issued in favour of an applicant (or applicants) and cannot be applied in general by other taxpayers.
They determine how SARS interpret and apply the relevant tax law’s provisions in relation to a proposed transaction.
A binding private ruling is published by consent of the applicant to which it has been issued. It has a binding effect between SARS and the applicant only, and is published for general information. It does not constitute a practice prevailing. A third party may not rely upon a binding ruling under any circumstances. In addition, published rulings may not be cited in any dispute with SARS, other than a dispute involving the applicant or any co-applicant(s) identified therein.