Draft Documents for Public Comment

All comments received on drafts are considered in full, but due to time constraints, no individual correspondence will be entered into. The identity of commentators and their comments will be collected and may be disclosed publicly, either in full or in summary, as legal obligation dictates or is necessary for SARS to properly perform its duties.

The draft documents are categorised according to their due date for comment. Comments may be emailed to the address indicated in the last column.

Latest draft uploaded for comment Look under: 10 October 2025

Due date for comments	Legislation	Description	Send comments to
12 September 2025	National Legislation	2025 Draft Tax Bills and Draft Regulations Media Statement: Publication of the 2025 Draft Tax Bills and Draft Regulations Media Statement: Retraction of the Proposal in Respect of the Definition of a Hybrid Equity Instrument in the 2025 Taxation Laws Amendment Bill (issued 3 September 2025) Draft Taxation Laws Amendment Bill, 2025 Draft Explanatory Memorandum on the Draft Taxation Laws Amendment Bill, 2025 Draft Tax Administration Laws Amendment Bill, 2025 Draft Memorandum on Objects of Tax Administration Laws Amendment Bill, 2025 Draft Domestic Reverse Charge Regulations, 2025 (updated 18 August 2025) Draft Export Regulations, 2025 Draft Explanatory Memorandum on the Draft Export Regulations, 2025 Explanatory Note National Treasury and SARS invite comments in writing on the 2025 Draft Taxation Laws Amendment Bill (2025 draft TLAB), 2025 Draft Tax Administration Laws Amendment Bill (2025 draft TALAB), Draft regulations on the domestic reverse charge issued in terms of section 74(2) of the Value-Added Tax Act, 1991, Draft regulations prescribing the application of paragraph (d) of the definition of “exported” in section 1(1) read with section 11(1)(a) of the Value-Added Tax Act, 1991. Date published: 16 August 2025	National Treasury’s tax policy depository at [email protected] and SARS at [email protected]
3 October 2025 New!	Customs & Excise Act, 1964	Draft Amendments to Rules Draft amendments to rules under sections 40, 41 and 120 – Insertion of rules under sections 40 and 41 relating to the manner in which bills of entry may be adjusted where customs value declared is affected by transfer pricing adjustments Comments on rules to be recorded on the Customs & Excise Rule Amendments Comment Sheet. Explanatory Note Draft rules have been inserted under sections 40 and 41 to explain how to adjust bills of entry when transfer pricing affects customs value. These rules outline the process for updating customs value by sending a notice to the Commissioner with amended invoices or debit/credit notes. They also explain what documents must be included, how to pay any duty and VAT owed after the adjustment, and how importers can apply for refunds if they overpaid due to transfer pricing changes. Date published: 12 September 2025	C&[email protected]
10 October 2025	Income Tax Act, 1962	Draft Interpretation Note Draft Interpretation Note 64 (Issue 5) – Income tax exemption: Bodies corporate, share block companies, and associations of persons managing the collective interests common to all members Explanatory Note This Interpretation Note provides guidance on the interpretation and application of section 10(1)(e), which exempts from income tax the levy income of a body corporate, a share block company, and any other association of persons. This Note is published as a draft for comment since technical changes were made, including the treatment of the carry-forward of assessed losses and retrospective approval of associations of persons. Date published: 27 August 2025	[email protected]

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