Tax Practitioner Connect Issue 39 (January 2023)

SARS releases Interpretation Note on Transfer pricing: Intra-Group Loans

The South African Revenue Service (SARS) has released an interpretation note titled “DETERMINATION OF THE TAXABLE INCOME OF CERTAIN PERSONS FROM INTERNATIONAL TRANSACTIONS: INTRA-GROUP LOANS” which provides guidance on how SARS will determine arm’s length pricing for intra-group loans. The note also provides guidance on the consequences for a taxpayer if the amount of debt, the cost of debt or both are not arm’s length.
See the full Media Release here.

Value-Added Tax (VAT) Customer Experience Study

Please take note that a survey will be distributed to a sample of VAT vendors. It is important for tax practitioners to make their clients aware of this in the event they receive this survey to complete.

Below is the wording for you to know it is a legitimate SARS letter, and not a scam.

Dear VAT Vendor,

SARS is conducting a customer experience survey and you have been selected to participate in the study. We kindly request your feedback on your interaction with SARS regarding your VAT registration. Your feedback will be used to understand your views and to help SARS improve on its VAT registration process.

Please be assured that your responses will remain anonymous, as the survey is completely confidential. If you would like to verify the authenticity of this email and the survey, please visit the SARS website at



For future studies, surveys, SMS and email campaigns from SARS, remember to visit our Current surveys, SMSs and Emails webpage.

Note:  The survey can only be completed if you were in the target VAT sample and received the link via email.

Have you or your clients received a Personal Income Tax Administrative Penalty notification?

If you or your client received a Personal Income Tax Administrative Penalty notification, please note that this was issued due to the late or non-submission of one or more Income Tax Returns.

To remedy this, please submit outstanding returns as soon as possible. Failure to do so will result in a monthly recurring admin penalty being levied until the non-compliance is remedied. For more information, visit the Admin Penalty webpage or log on to your eFiling profile to view your personalised admin penalty notice. You can submit your outstanding returns via eFiling or the SARS MobiApp.

SARS payment rules

SARS published an external guide for payment rules in 2022. To access, please click the link: GEN-PAYM-01-G01 – SARS Payment Rules – External Guide

Latest Scam

The latest scam appears to be a SMS from SARS, indicating a payment to be received from SARS via Pay_Fast. Please don’t click on any links and report any suspicious correspondence from SARS to [email protected]. See an example of the Pay_Fast scam here.

Webinar for taxpayers in the arts, entertainment and sports sector

SARS held a webinar for taxpayers in the arts, entertainment and sports sector. The video recording can be accessed at YouTube link:

Attribution of nett income to a public benefit organisation

This ruling determines the tax consequences of a public benefit organisation holding a participatory interest in a controlled foreign company, which is a foreign incorporated charity. The ruling can be accessed by clicking on the link: Binding Private Ruling 387 – Attribution of nett income to a public benefit organisation.

Rebate and deduction for foreign taxes on income

This Interpretation Note explains the scope, interpretation and application of section 6quat which provides for a rebate or deduction for foreign taxes on income. It can be accessed by clicking on the link: Interpretation Note 18 (Issue 5) – Rebate and deduction for foreign taxes on income.

Latest SMME Connect Newsletter is available

The December 2022 issue of the SMME Connect is now available and contains useful information for SMME taxpayers. The latest edition contains information on the risks of using non-registered individuals who practice as tax practitioners, VAT obligations for SMMEs, tax compliance status verification and information on corporate income tax.

VAT Connect Newsletter

The December issue of the VAT Connect newsletter is now available.

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