Legal Counsel – International Treaties & Agreements – Double Taxation Agreements & Protocol – Multilateral Instrument (MLI)
31 March 2025 – Income Tax Act, 1962
Multilateral Instrument (MLI) synthesised texts:
- Croatia
- Seychelles
- Tunisa
Legal Counsel – Interpretation and Rulings – Binding Private Rulings 401–420
31 March 2025 – Income Tax Act, 1962
- Binding Private Ruling 414 – Application of the proviso to section 8EA(3)
Legal Counsel – Interpretation and Rulings – Binding Class Rulings 81–100
31 March 2025 – Income Tax Act, 1962
- Binding Class Ruling 092 – Application of the proviso to section 8EA(3)
Tax Directives: Trade Testing of Interface specification version 6.803
31 March 2025 – The South African Revenue Service (SARS) is preparing to implement enhancements to the Tax Directives process as indicated in the IBIR-006 Tax Directives Interface Specification Version 6.803. To access the Tax Directives Interface Specification, visit www.sars.gov.za, go to the “Individuals” page through the top-most menu, and choose “I want to get a tax directive”. We strongly recommend that you review IBIR-006 before proceeding with testing.
This version will resolve the issues encountered in the previous version regarding reason 54 and 48 transfers.
Trade testing began on 24 March 2025 and will run until 7 April 2025.
Latest Tax Practitioner Connect newsletter now available
31 March 2025 – In this edition, we provide clarity and certainty about Donations Tax and we explore the different options to find out if you owe SARS any money.
Media release: Trade Statistics for February 2025
31 March 2025 – South Africa recorded a preliminary trade balance surplus of R20.9 billion in February 2025. This surplus was attributable to exports of R164.0 billion and imports of R143.1 billion, inclusive of trade with Botswana, Eswatini, Lesotho and Namibia (BELN).
See the full Media Release here.
Or visit the Trade Statistics webpage.
Prohibited and Restricted Imports and Exports list
31 March 2025 – Prohibited and Restricted Imports and Exports list
Tariff heading 7204.21 needs an ITAC Export permit.
Customs Weekly List of Unentered Goods now available
31 March 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.
Legal Counsel – Dispute Resolution & Judgments – Supreme Court of Appeal: 2025–2023
28 March 2025 – Value-Added Tax Act, 1991
Value-Added Tax Act 89 of 1991 (the Act) – vendor conducting enterprise of shaft sinking and mining construction activities – whether input tax on charges for accommodation and food acquired by vendor for specific project employees deductible from output tax – s 17(2)(a)(i)(bb) of the Act – whether accommodation and food acquired for making taxable supplies of entertainment in the ordinary course of vendor’s enterprise – whether supplied to employees for a charge – if so, whether all direct and indirect costs of such entertainment covered.
Legal Counsel – Dispute Resolution & Judgments – High Court: 2025–2023
28 March 2025 – High Court Judgments
- Cell C (Pty) Ltd v CSARS (30959/2019) [2025] ZAGPPHC 265 (17 March 2025)
- Biskit (Pty) Ltd v CSARS (6156/2023) [2025] ZAFSHC 71 (13 March 2025)
- CSARS v ASPASA NPC and Others (Leave to Appeal) (2023/099811) [2025] ZAGPPHC 223 (5 March 2025)
- Woods Warehousing (Pty) Ltd v CSARS and Others (2022/026798) [2025] ZAGPPHC 162 (14 February 2025)
- Naude v CSARS and Another (51712/2017) [2025] ZAGPPHC 152 (13 February 2025)
- Greyvensteyn and Other v CSARS and Others (B2495/2023) [2025] ZAGPPHC 128 (12 February 2025)
- FTTX and Energy Warehouse (Pty) Ltd v CSARS (2022/5522) [2025] ZAGPPHC 140 (31 January 2025)
- Sandbaken Boerdery (Pty) Ltd v CSARS and Another (053180/2022) [2025] ZAGPPHC 54 (21 January 2025)
Summaries are available on the High Court Judgments page
Legal Counsel – Dispute Resolution & Judgments – Tax Court: 2025–2023
28 March 2025 – Tax Administration Act, 2011
Procedure: Whether the court should go behind the documents discovered by SARS and order it to discover more documents which the applicant contends should be in existence and in the possession of SARS; and whether SARS should be ordered to discover the documents which it has discovered but in a different format as requested by the applicant.
Legal Counsel – Interpretation and Rulings – Interpretation Notes 121–140
28 March 2025 – Mineral and Petroleum Resources Royalty Act 28, 2008
- Interpretation Note 138 – Determining the calorific value of coal for purposes of the royalty
Legal Counsel – Interpretation and Rulings – Value-Added Tax Rulings (VRs) 1–20
28 March 2025 – Value-Added Tax Act, 1991
- VR 009 – Application of the zero rate to the services supplied directly in respect of investments located outside the Republic of South Africa and not listed on a South African Stock Exchange.
Employment Tax Incentive (ETI) changes with effect from 1 April 2025
28 March 2025 – The proposed amendments to the ETI Act in the 2025 Draft Rates and Monetary Amounts and Amendment of Revenue Laws Bill will be effective 1 April 2025.
The amendments from 1 April 2025 are as follows:
Section 4(1)(b)(i) and (ii):
“(i) where the employee is employed and paid remuneration for at least 160 hours in a month, the amount of R2 500 (previously R2 000) in respect of a month; or
(ii) where the employee is employed and paid remuneration for less than 160 hours in a month, an amount that bears to the amount of R2 500 (previously R2 000) the same ratio as 160 hours bears to the number of hours that the employee was employed for and paid remuneration by that employer in that month.”
Section 6(g):
“(g) receives remuneration in an amount less than R7 500 (previously R6 500) in respect of a month”
Section 7:
The determination of ETI as per section 7 of the ETI Act from 1 April 2025 is as follows:
| Monthly remuneration | Formula
First 12 months |
Formula
Second 12 months |
| R0 — R2 499.99 | 60% of monthly remuneration | 30% of monthly remuneration |
| R2 500 — R5 499.99 | R1 500 | R750 |
| R5 500 — R7 499.99 | R1 500 — (75% x (monthly remuneration — R5 500)) | R750 — (37,5% x (monthly remuneration — R5 500)) |
Note: These amendments will apply for a period of 12 months provided Parliament pass the necessary legislation giving effect to the announcement in the national annual budget within that period of 12 months.
See the Employment Tax Incentive (ETI) webpage for more information.
Starts soon! Employer Annual Declarations (EMP501): 1 April to 31 May 2025
28 March 2025 – Dear Employers, your tax compliance helps SARS to achieve its Higher Purpose, which is to enable the state to provide for the well-being of all South Africans. One of SARS’s strategic objectives is to improve our service to deliver a seamless taxpayer experience that provides clarity and certainty. This letter guides you on how to fulfil your tax obligations during the Employer Annual Declaration period.
See what is new this year, how to submit, more about penalties and more, click here.
Legal Counsel Publications – Find a Guide – Customs and Excise
27 March 2025 – Customs and Excise Act, 1964
Customs and Excise – Updated Bonds Policy
27 March 2025 – The Bonds policy has been amended to:
- Provide clarity on consignor bonds
- Explain the rule for the correction of surety bonds.
- Include Rule 12.08.
- Remove financial institution and bank names.
Legal Counsel – Secondary Legislation – Regulations (2025)
26 March 2025 – National Legislation: The following regulations have been promulgated:
Effective 1 April 2025
- Regulations with regards to value-added tax for casino table games of chance issued in terms of section 74(2) of the Value-Added Tax Act, 1991 (Act No. 89 of 1991)
- Regulations prescribing electronic services for purposes of the definition of “electronic
services” in section 1(1) of the Value-Added Tax Act, 1991 (Act No. 89 of 1991)
Effective 1 January 2025
- Regulations with regards to value-added tax on domestic reverse charge relating to valuable metal issued in terms of section 74(2) of the Value-Added Tax Act, 1991 (Act No. 89 of 1991)
Effective 1 January 2024
- Regulations under section 19(c) of the Carbon Tax Act, 1991 (Act No. 15 of 2019)
Legal Counsel – Interpretation and Rulings – Interpretation Notes 121–140
26 March 2025 – Income Tax Act, 1962
- Interpretation Note 137 – Recoupment of amounts deducted or set off when an asset commences to be held as trading stock
PAYE Employer Reconciliation BRS for the 2026 tax year
26 March 2025 – The PAYE Employer Reconciliation BRS v24 0 0 has been published. The following changes are applicable from 1 March 2025:
- New source codes: 3623/3723, 4042, 4588, 4589
- Amended description: 3020, 3907
- Amended validations: 3230, 3232
