Tax Practitioner Connect Issue 36 (September 2022)

SARS Tax Practitioner Readiness Programme

As communicated in previous Tax Practitioner Connects (TPCs) effective 1 July 2022, a member of an RCB who wishes to register as a tax practitioner is required to successfully pass the assessment for the SARS Tax Practitioner Readiness Programme. The learning material is available on the SARS website and SARS YouTube TV Channel. 

On the 30th of August, SARS hosted a virtual session which was attended by individuals awaiting registration as tax practitioners, and some registered tax practitioners who wanted to refresh their knowledge. A virtual session covering the same topics will be held on 27 September 2022.

From the questions raised by attendees of the previous sessions, SARS has compiled and published FAQs for the programme. The FAQs may be accessed per the link: SARS Tax Practitioner Readiness Programme | South African Revenue Service

Tax practitioners as registered representatives for deceased estates

Tax practitioners have raised a number of queries concerning their role in working with deceased estates. SARS confirms that the registered representative for a deceased estate is the executor, who is appointed by the Master of the High Court. Therefore, a tax practitioner, who is the appointed executor, can be a registered representative for a deceased estate. For more information and FAQs on Estates click here.

Information on registered representatives can be found on page 13 and 14 of the guide.

FAQs on 2022 Filing Season

Communication sessions were held with tax practitioners on the changes to the filing season. Frequently asked questions were raised and responses to these are contained below:

Auto Assessments


There are instances where information per the IRP5s and IT3bs of taxpayers are not appearing on the system. Where changes were made, the system ignored these and issued the original auto assessment.


The auto assessments are issued based on the third party data provided to SARS. Any changes made are verified against the third party data. If changes are made and these do not conform with third party data, the original assessment will be issued.

Taxpayers are required to contact the institutions and request them to send the updated data to SARS and to themselves. When the updated third party data is received after the auto assessment (or where the taxpayer submitted a return that was already assessed), a notification will be sent to the taxpayer requesting him/her to review the correctness, and the taxpayer may lodge a Request for Correction. If the taxpayer does not do anything, SARS will proceed to auto revise the return.

Question: Why has SARS taken away the option to ‘accept’ or ‘decline’? If SARS brings back these options, tax practitioners believe they will automatically have the later deadline available as opposed to having to submit the return within 40 business days of the assessment.


SARS removed the “accept” option on the eFiling system in the filing season based on the observations from the 2021 filing season, where 96% of taxpayers who were auto assessed did not amend their returns prepopulated by SARS. If taxpayers are unhappy with the auto assessments, they can submit the returns in the normal way (i.e., open the return and make the changes).

Question: What triggers a manual intervention and what is the timeframe for finalisation of an assessment in such circumstances?


A manual intervention is triggered if a risk is identified. The taxpayer will be requested to submit supporting documents. The turnaround time is 21 business days from the date when all required documents are submitted to SARS.

Question: Some of the information reflected on an IT3b is not included on the pre-populated ITR12. Why would this happen?


There are two categories of reasons why third party data is not pre-populated on a return:

    • The third party has not submitted the data to SARS at all or the information was submitted to SARS after the auto assessment was done.
    • The third party submitted the data to SARS, but the information could not be prepopulated because it does not reach the level of confidence acceptable to SARS.

A taxpayer may use the enquire third party data functionality on eFiling to see if the information he/she is looking for is on the system. If it is, the taxpayer needs to click on refresh data and the information will then be pre-populated on the return,

Question: In respect of medical aid contributions, the question on the return asks how many dependents the taxpayer has and not how many members are on the medical aid.


The ITR12 return form was amended a few years ago to align to the medical aid reporting. When the medical aid reports the data, they show the number of dependents (including the main member). The current return asks for number of dependents (including the main member), so the return is very specific as to what is required.

Supporting Documents

Question: Most financial institutions have the practice of providing to a taxpayer a password protected document. Since SARS does not allow the uploading of such a document in response to a query, how does SARS suggest that the supporting documentation be provided in a form other than the original document, bearing in mind that not everyone has the ability to print and then scan the print for submission?


Choose Print to PDF option, then save the document.

Tax Residency 

Question: It seems that the change in tax residency status cannot be declared in the 2022 tax return.


This has to be done on the RAV01 form.

Important dates for provisional taxpayers

The following dates are important for tax practitioners when representing clients who are provisional taxpayers. For the 2023 tax year which runs from 01 March 2022 to 28 February 2023, provisional taxpayer deadlines and obligations are:

28 February 2023

Second provisional tax return on an IRP 6 and second payment. If your estimated taxable income is nil, you still are required to submit a return.

30 September 2023

An optional top up payment if you end up owing additional tax after your provisional tax returns are assessed

January 2024

(Date set by the Commissioner)

Submit your annual income tax return (ITR12) for the 2023 tax year

For the 2022 tax year which ran from 01 March 2021 to 28 February 2022, your tax obligation is:

24 October 2022

Non-provisional taxpayers for manual submission of annual income tax returns (ITR12s)

23 January 2023 (this year’s filing season)

Provisional taxpayers for the submission of annual income tax returns (ITR12s)

Note: Provisional tax must be activated on your eFiling profile before you can request an IRP 6 provisional tax return.

What’s new?

As part of the SARS modernisation journey and to make it easy to comply with tax obligations, the following changes that will impact tax practitioners have been introduced:

  • Supplementary declaration for companies or close corporations (IT14SD) form

From 16 September 2022, SARS no longer requires a Company/Close Corporation to submit the Supplementary Declaration for Companies or Close Corporations (IT14SD) when identified for a verification. This requirement will be replaced by a SARS letter requesting specific, relevant documents based on the reason for verification. For more information click here.

  • Excise news – taxing of alcohol powder products

The current excise duty regime applies a flat excise rate of 34.7c/kg for traditional African beer powder. As there are similar products on the market, and in the interest of equity, these alcohol powder products will be included in the tax net with an excise rate equivalent to that of the traditional African beer powder from 1 October 2022. In terms of the National Treasury’s proposal, alcohol powder products classified as preparations for use in the manufacturing of alcoholic beverages will be taxed. See the letter to Trade here.

Delay in implementing the automated refunds and drawback system SARS Customs and Excise is enhancing current systems with modern, automated systems to facilitate legitimate trade and travel.

The refunds and drawback process is being automated as part of this modernisation. Previous communication indicated that the system would go live on 19 September 2022. The implementation date has been postponed due to the following reasons:

    1. To allow an additional period for trade testing
    2. To consider additional feedback from various stakeholders, and
    3. To allow additional time to make changes to the development of the system resulting from additional enhancements to the design.

For more information, see the letter to Trade.

  • Employer Interim Reconciliation Filing Season

This year, the Employer Interim Reconciliation Declaration (EMP501) submission period opens on 19 September 2022 and closes on 31 October 2022. Employers are required to reconcile their Monthly Employer Declarations (EMP201) for the first six months of a Reconciliation Year (1 March 2022 to 31 August 2022). These reconciliations are based on the Monthly Employer Declarations (EMP201) submitted, with the tax values of the interim IRP5/IT3(a)s certificates generated, accurate payroll information, employees’ tax (PAYE) payments made, thereafter an Employer’s Reconciliation Declaration (EMP501) is submitted. Click here for more information on the employer interim reconciliation submission.

The following enhancements have been implemented for the interim PAYE Filing Season:

  • New fields are added on the IRP5/IT3(a) certificates.
  • Amendments to validation rules for certain fields on the IRP5/IT3(a) certificates.
  • Enhancement to EMP201 and EMP501 request processes.
  • Employment Tax Validation on EMP501 Reconciliation.
  • Backdating of PAYE liability date.
  • Enhancements to Employer de-registration process.

The following Guides were updated:

  • Foreign suppliers of electronic services

The guide, Foreign Suppliers of Electronic Services, has been revised to include a process for cancellation of VAT .

  • SARS Pavilion branch office

The SARS Pavilion branch in Pretoria has been permanently closed, but staff continue to service clients. Tax practitioners are advised to book appointments via the usual channels if they need assistance from SARS. (If they book via the SARS website: SARS Booking System, they should continue to choose the “Pavilion” option).


  • Draft document for public comment

Value-Added Tax Act, 1991: SARS has published, for public comment, the Draft interpretation note on the value-added tax treatment of debt collection. Click on the link to access the draft interpretation note. Due date for comment is 7 October 2022.

  • Published binding rules – binding class rulings (BCRs) – BCR 61-80

Income Tax Act, 1962, and Estate Duty Act, 1955 BCR 080 – Tax implications for resident beneficiaries of a foreign pension trust.

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