Updated Guide for Foreign Supplier of Electronic Services
31 October 2025 – The newly developed “Supply of Electronic Services by Foreign Suppliers and Foreign Intermediaries” external guide has been updated to align with the legislative amendments. Any queries relating to Foreign Suppliers of Electronic Services and Foreign Intermediaries must be referred to the Large Business and International (LBI) service centre.
The update includes the following details:
- Section 23(2)(a) and section 46(2) of the Value-Added Tax Act were amended, with effect from 24 December 2024, to allow for the appointment of a natural person who is a non-resident of the Republic as a representative vendor for a Foreign Supplier of Electronic Services or Foreign Intermediary.
- A new proviso has been added to section 23(2) of the VAT Act stipulating that a foreign enterprise will not be required to open a South African (SA) bank account, provided that the enterprise resides in countries that have a Double Taxation Agreement (DTA) with SA in terms of section 108(2) of the Income Tax Act or section 75(2) of the VAT Act. However, section 23(2)(b) of the VAT Act shall not apply in the following circumstances:
- If a company, is an “external company” defined in section 1 of the Companies Act (2008), and it does not have a fixed or permanent place of business in SA;
- If a natural person is physically present in SA for a period less than an accumulated period of six months in any period of 12 months;
- If the person is defined as an “enterprise” in terms of paragraph (b)(vi) of section 1 of the VAT Act.
- Furthermore, where the non-resident of SA no longer complies with the requirements of the provision to section 23(2B) of the VAT Act, normal rules for the representative vendor and banking details must apply with effect from the date of such non-compliance, where such date is after 24 December 2024.
- The definition of “electronic services” was amended in section 1(1) of the VAT Act to include electronic agent, electronic communication or internet.
- A new definition of “content” was added to section 1(1) of the VAT Act.
- The updates also highlight that a credit for a Foreign Supplier of Electronic Services will not be refunded; it is offset against future VAT liabilities. However, where a Foreign Supplier of Electronic Services is deregistering for VAT in SA, any credit will be refunded to the foreign bank account of that Foreign Supplier of Electronic Services.
Updated guide: VAT-REG-02-G02 – Supply of Electronic Services by Foreign Suppliers and Foreign intermediaries – External Guide
Legal Counsel – Interpretation and Rulings – Interpretation Notes 141–160
31 October 2025 – Income Tax Act, 1962
- Interpretation Note 141 – The meaning of reserve fund under section 23(e)
Legal Counsel – Preparation of Legislation – Draft Documents for Public Comment
31 October 2025 – Customs and Excise Act, 1964
- Draft amendments to rules and forms under sections 15 and 120 – Implementation of the South African traveller management system
Due date for comment: 21 November 2025
Legal Counsel – Secondary Legislation – Tariffs Amendments 2025
31 October 2025 – Customs and Excise Act, 1964: Publication details for tariffs amendments notices R6768 (GG 53600) and R6783 (GG 53606), published on 31 October 2025, are now available.
Media Release: Trade Statistics for September 2025
31 October 2025 – South Africa recorded a preliminary trade balance surplus of R21.8 billion in September 2025. This surplus was attributable to exports of R186.4 billion and imports of R164.6 billion, inclusive of trade with Botswana, Eswatini, Lesotho and Namibia (BELN).
For more detail, see the full Media Release.
Visit the Trade Statistics webpage.
Customs – Registration, Licensing and Accreditation
31 October 2025 – The facility codes used in Box 30 on the Customs Clearance Declaration (CCD) has been updated to include details of the de-grouping facility for Pro-Logistics Forwarding (Pty) Ltd, located at O. R. Tambo International Airport.
This addition enables Customs to transmit electronic messages communicating the status of the consignment to these facilities.
Latest SARS Annual Report 2024/2025
30 October 2025 – The SARS Annual Report for 2024/2025 has been published. The Strategic Plan End-Term Report for 2020 – 2025 is also available now:
Legal Counsel – Secondary Legislation – Tariffs Amendments 2025
30 October 2025 – Customs and Excise Act, 1964:The tariffs amendments notices, scheduled for publication in the Government Gazette, relate to the imposition of –
- provisional payment in relation to anti-dumping duties against the alleged circumvention of the anti-dumping duties on windscreens for vehicles classifiable under tariff subheading 7007.21.20 originating in or imported from the Peoples Republic of China by importing the windscreens under tariff subheading 8708.22.10 – (ITAC Report No. 756); and
- provisional payment in relation to anti-dumping duties against the alleged circumvention of the anti-dumping duties on windscreens for vehicles, classifiable under tariff subheadings 7007.21.20 and 8708.22.10, through country hopping originating in or imported from the People’s Republic of China via Malaysia – (ITAC Report No.757)
Publication details will be made available later.
SARS Digital platform upgrades on 31 October to 1 November 2025
30 October 2025 – Achieving our Vision of a smart, modern SARS with unquestionable integrity that is trusted and admired is of paramount importance. Pivotal to the delivery of our vision are our digital platforms and technology infrastructure. To provide clarity and certainty, make it easy for taxpayers and traders to comply with their obligations and building public trust and confidence, our technology assets must demonstrate the highest levels of availability, robustness and security.
In accordance with our Vision and Strategic Objectives, which include modernising our systems to provide Digital and Streamlined online services, we are hard at work ensuring that our digital platforms and technology infrastructure are available, robust and secure, by performing regular upgrades, enhancements and maintenance.
Considering the above, SARS Digital platform maintenance are scheduled for:
Friday, 31 October 2025 from 17h00 to 19h00
Saturday, 1 November from 05h00 to 10h00
During this time, you may experience intermittent service interruption on our eFiling, Tax and Customs Digital Platforms.
Update on the GloBE project implementation timeline
30 October 2025 – SARS has rescheduled the launch of the GloBE registration and notification functionality on eFiling from December 2025 to 16 March 2026. This adjustment ensures system quality and compliance with international standards. For queries, contact [email protected].
For details on revised deadlines and next steps, see the Global Minimum Tax webpage.
Media Statement on Roy Muleya’s sequestration
29 October 2025 – The South African Revenue Service (SARS) welcomes the judgment handed down on 29 October 2025 by the High Court of South Africa, North Gauteng (case no. 48495/2020). This decision came because of an application brought by SARS for the sequestration of Mr Roy Muleya.
Mr Muleya was found to be one of the main role players in a scheme which involved the importation of tobacco by entities who had no obvious links to registered cigarette manufacturers.
Mr Muleya was issued with a section 103 notice in terms of the Customs and Excise Act in respect to a company with a liability amounting to ±R155 million. He is the sole director of the company.
SARS instituted a sequestration application against Mr. Muleya in terms of section 177 of the Tax Administration Act during September 2021.
The application was heard on 24 May 2023, and the judgment was issued on 29 October 2025, granting the provisional sequestration of Mr. Muleya.
This success points to the intentional strategy adopted by SARS to emphatically deal with those who have opted to operate outside of the law. SARS seeks to always provide clarity and certainty to taxpayers so that they know what their legal obligations are. This is accompanied by providing digital platforms, which makes meeting their obligations easy. Where taxpayers opt to wilfully disregard their obligations by acting outside the remit of the law, SARS will make it hard and costly. All these efforts are undertaken to foster a culture of voluntary compliance. This is to ensure that all taxpayers meet their obligations in an equitable manner, without burdening compliant taxpayers with a disproportionate burden of paying taxes.
Commenting on the matter, SARS Commissioner Edward Kieswetter stated:
“SARS will relentlessly pursue legally all those who are disregarding the law by seeking to bypass it. South Africa has seen proliferation of illicit tobacco and cigarettes, and the action of Mr Muleya only exacerbates this challenge. Bringing cigarettes illegally in the country threatens the health of smokers and undermine national fiscus by withholding excise duties. SARS will continue to act lawfully and decisively against those who deliberately seek to evade or neglect their tax responsibilities. The message we want to communicate is that no matter how long it takes, SARS will not abdicate its responsibility to enforce the law. We will do so responsibly and without prejudice, fear or favour. For all are equal before the law”.
Commissioner also appealed to smokers “Whilst it is your decision to smoke, I want to direct you to resist the temptation to support the production and sale of illicit tobacco products. In doing so, you are inadvertently complicit in a criminal syndicate” he concluded.
For any further comment please contact: [email protected].
Legal Counsel – Secondary Legislation – Public Notices 2025
28 October 2025 – Tax Administration Act, 2011: Public Notice 6763 of Government Gazette 53590 of 28 October 2025, published in terms of section 25(7), extending the due date for notices and the due date for GLOBE Information Returns for the Fiscal Year commencing on or after 1 January 2024 but before 1 January 2025.
Customs Weekly List of Unentered Goods now available
27 October 2025 – The state provides state warehouses for the safekeeping of goods. These are managed by Customs. The purpose of this list of unentered goods is to notify the importer, exporter and any other person that has interest in the goods that the goods have been taken up into the State warehouse and if they remain unentered they will be disposed in accordance with the provisions of the Customs & Excise Act.
See the latest Customs Weekly List of Unentered Goods here.
Media release: South Africa’s exit from the FATF grey list
24 October 2025 – The South African Revenue Service (SARS) today welcomes the decision by the Financial Action Task Force (FATF) to delist South Africa from its “grey list” of jurisdictions under increased monitoring. This is a significant moment for our country and a testament to the whole of government approach and its institutions to restore the integrity of our financial system.
While the FATF’s initial grey-listing in February 2023 was a consequence of systemic weaknesses aggravated during the era of state capture, SARS is acutely aware that it, along with other key institutions, was impacted and must continue to play a crucial role in preventing any future regression. Commissioner Edward Kieswetter notes that “we recognise that removing the designation of grey listing is not a finish line but a milestone on a long-term journey toward building a robust and resilient financial ecosystem”.
SARS is proud to have supported the national effort to meet the 22 action items required by the FATF. Our specific contributions include:
- Enhanced investigation and collaborate recovery: In partnership with other law enforcement agencies through forums such as the National Priority Crime Operational Committee (NPCOC), the National Joint Operational and Intelligence Structure (NATJOINTS), the Inter-Agency Working Group on Illicit Financial Flows, the Fusion Centre, the South African Anti-Money Laundering Integrated Taskforce (SAMLIT), Inter-Agency Working Group on Illegal Money or Value Transfer Services (MVTS) and the State Capture Task Force, SARS has strengthened its financial intelligence-gathering capabilities and increased investigations and asset preservation/recovery in relation to tax and customs crime matters involving complex money laundering and terror financing schemes.
- Increased access to beneficial ownership information:We have introduced beneficial ownership reporting obligations for legal persons and trusts as well as collaborated closely with the Companies and Intellectual Property Commission (CIPC) and the Master of the High Court (MOHC) to improve access to accurate and up-to-date beneficial ownership information for legal persons and trusts.
- The introduction of key legislative amendments: The Tax Administration Act was amended in 2023 to enable information exchange with CIPC, MOHC and the Department of Social Development (DSD) further supporting the national beneficial ownership information framework.
- The rollout of a Traveller Management System: The development and piloting of a digital traveller declaration system for cash and bearer negotiable instruments (BNIs) on entry and exit at all borders. This system enables the sharing of information with the FIC and is expected to become mandatory by the end of 2025.
- Capacity building (joint and SARS driven): SARS provided training to its officials as well as other law enforcement officials on money laundering, beneficial ownership, legal gateways for information exchange and the application of mutual legal assistance. This aligns with SARS’s broader strategy to use data-driven insights and sophisticated technology to detect and combat tax evasion and other financial crimes.
SARS’s focus now shifts to embedding these improvements permanently and sustainably into our operational DNA. This means continuing to:
- Make it clear and easy for taxpayers to comply with their obligations to pay tax.
- Enforce our tax and customs laws decisively and fairly without fear, favour, or bias.
- Cooperate effectively with domestic and international partners in combatting the illicit economy.
- Utilise sophisticated data and business intelligence to understand and counter illicit financial flows.
Commissioner Kieswetter says that “this delisting is a vote of confidence in South Africa’s progress, but it is not an end to our vigilance. The fight against financial crime and corruption is a continuous one. SARS remains committed to upholding the highest standards of financial integrity and, as we approach the new round of FATF review commencing in the latter part of 2026, SARS will work relentlessly to ensure that we do what is required to combat the illicit economy. By doing so, we will not only maintain our standing with FATF but, more importantly, continue to build public trust and confidence in our financial system, and create a stronger, more prosperous South Africa for all.”
For further media enquiries, please contact SARS at [email protected].
Legal Counsel – Secondary Legislation – Income Tax Notices 2025
24 October 2025 – Income Tax Act, 1962:
- Notice published in terms of section 18A(2)(a)(vii) prescribing the further information that must be contained in a receipt issued in terms of section 18A(2)(a) of the Act
Legal Counsel – Secondary Legislation – Tariffs Amendments 2025
24 October 2025 – Customs and Excise Act, 1964: Publication details for tariffs amendments notice R6756, as published in Government Gazette 53572 of 24 October 2025, are now available.
Legal Counsel – Secondary Legislation – Tariffs Amendments 2025
23 October 2025 – Customs and Excise Act, 1964: The tariffs amendments notice, scheduled for publication in the Government Gazette, relates to the amendments to –
- Schedule No 1, by the substitution of paragraph 1 of General Note O, to include Ethiopia as part of the State Parties in the African Continental Free Trade Area (AfCFTA) Agreement. (With retrospective effect from 14 August 2025)
Publication details will be made available later
Legal Counsel – Dispute Resolution & Judgments – High Court 2025–2023
23 October 2025 – Tax Administration Act, 2011
- Ditsoane Trading Project CC v CSARS (4438/2023) [2025] ZAFSHC (18 September 2025)
- Ditsoane Trading Project CC v CSARS (4438/2023) [2025] ZAFSHC 260 (29 January 2025)
Summaries are available on the High Court Judgments page
Scam alert: Letter stating ‘Final Demand – Debt Management’
22 October 2025 – Beware of a PDF letter being emailed to people with the email subject line ‘LEGAL RULING SUMMON DEMAND AS AT 21 10 2025’. Scams are changed on a regular basis so the subject line may differ. The letter contains a link to a fraudulent phishing website. Please do not click on any links. You should always type in the SARS eFiling address in your browser or click on the eFiling login from the SARS website homepage (sars.gov.za). If in doubt, go to our Scams and Phishing webpage where we will publish some examples or forward the suspicious email to [email protected].

Customs Weekly List of Unentered Goods now available
21 October 2025 – The state provides state warehouses for the safekeeping of goods. These are managed by Customs. The purpose of this list of unentered goods is to notify the importer, exporter and any other person that has interest in the goods that the goods have been taken up into the State warehouse and if they remain unentered they will be disposed in accordance with the provisions of the Customs & Excise Act.
See the latest Customs Weekly List of Unentered Goods here.