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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.
- Read more about Advance Tax Rulings.
| 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 |
