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Rulings

Chapter 7 (sections 75-90) of the Tax Administration Act, 2011 governs the issuing of advance rulings.

Applications for advance rulings are done through eFiling, so you have to be registered as an eFiler first.

​Type of ruling​Description​Binding effect

​Advance ruling

​An advance ruling may be any one of the following:

​The binding effect differs per type
Binding General Ruling (BGR)​A written statement issued by a senior SARS official under section 89 regarding the interpretation or the application of a tax Act to the stated facts and circumstances​On SARS and all qualifying taxpayers
Binding Private Ruling (BPR)​A written statement issued by SARS regarding the application of a tax Act to one or more parties to a ‘proposed transaction’, in respect of that ‘transaction’​On SARS and the applicant
Binding Class Ruling (BCR)

​A written statement issued by SARS regarding the application of a tax Act to a specific ‘class’ of persons in respect of a ‘proposed transaction’

​On SARS and the specific ‘class’ of persons
​Non-binding private opinion​Informal guidance issued by SARS in respect of the tax treatment of a particular set of facts and circumstances or ‘transaction’, but which does not have a binding effect within the meaning of section 88​None, but may be cited in proceedings involving the person to whom the opinion was issued

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