Legislative Engagements

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Re: Support Program For Industrial Innovation (SPII) – Discussion on Challenges Faced by Applicants

Mar 31, 2025

THE DEPARTMENT OF TRADE, INDUSTRY AND COMPETITION

As incentives consultants, it is our role to work together with clients and guide them through the application processes as set out by the DTIC. During the financial year 2019/2020 applicants for DTIC incentive programmes, particularly the Support Program for Industrial Innovation (“SPII”), have been experiencing several challenges.

System Challenges Regarding Reinstatement of Tax Practitioners with Updated Passport Numbers

Jan 30, 2025

SAIT submitted a request to SARS highlighting a system issue affecting tax practitioners whose passport numbers change after visa renewals. Updated passport numbers are not automatically linked to existing Practice Registration (PR) numbers in SARS systems, disrupting access to services. SAIT requests system enhancements to link old and new passport numbers and interim guidance to support affected practitioners.
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SAIT Submission_Draft amendments to rules under sections 77H and 120 – Internal administrative appeal

May 5, 2025

The South African Institute of Taxation (SAIT) has reviewed the draft amendments to the rules under sections 77H and 120 of the Tax Administration Act, focusing on the internal administrative appeal process. The submission highlights key areas of concern regarding procedural fairness, clarity of timelines, taxpayer rights, and administrative efficiency. SAIT supports the intent to streamline dispute resolution but recommends specific adjustments to ensure the rules uphold principles of transparency, consistency, and equitable treatment for taxpayers.
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SAIT-Presentation-on-the-Fiscal-and-Revenue-Proposals-2025

Apr 2, 2025

The SAIT Presentation on the Fiscal and Revenue Proposals 2025, highlights the negative impacts of the upward trajectory of the country’s expenditure and the negative long-term effect that the growing debt-service costs will have on the economy. The presentation highlights the impact of the VAT increase on middle and lower-income taxpayers, emphasising the strain on discretionary spending. It discusses the lack of inflationary adjustments to personal income tax brackets, which we believe will continue to exacerbate economic inequality. In our presentation to the Standing and Select Committee on Finance, SAIT called for the modernisation of SARS’s systems, enhanced taxpayer rights, and the introduction of a withholding tax on tenderpreneurs to ensure compliance. Our presentation also underscores our support for the significant public-sector infrastructure investment and improved customs and excise enforcement to promote economic growth and transparency.

SAIT Submission_Potential for Double Taxation Arising from Trust Distributions

Feb 27, 2025

SAIT submitted concerns to SARS about potential double taxation arising from trust distributions. The submission outlines how current tax rules—particularly Section 7C of the Income Tax Act and estate duty provisions—can result in both annual donations tax on interest-free loans and estate duty on the same amounts or growth, without offset. SAIT highlights unintended tax consequences of automatic trust distributions and calls for a review to prevent double taxation and ensure fair tax treatment.
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SAIT Submission_Taxation of Alcohol Beverages

Feb 14, 2025

The South African Institute of Taxation (SAIT) has submitted its official comments on the Taxation of Alcoholic Beverages Discussion Paper released by the National Treasury on 13 November 2024.This submission was compiled by the SAIT Customs and Excise Technical Workgroup and aims to provide insightful, practical feedback on the proposed reforms outlined in the Discussion Paper. Our response reflects the views of industry professionals and stakeholders committed to fostering a fair, transparent, and economically sound tax framework for the alcoholic beverage sector.We appreciate the opportunity to engage with the National Treasury on this important matter and trust our comments will be of value in shaping the way forward.

SAIT Submission_ Commentary on the amendments to Form DA 5

Feb 14, 2025

SAIT submitted commentary to SARS regarding the revised draft amendments to Form DA 5, which concerns the declaration of sealable goods on ships. Initially, SAIT had concerns about the legal alignment of the amendment. However, after reviewing the updated draft (published 6 February 2025), SAIT confirmed that their concerns were addressed and expressed support for the revised form, commending SARS for incorporating their earlier feedback.

SAIT Submission_ Carbon Tax Phase II Discussion Commentary

Dec 13, 2024

The South African Institute of Taxation (SAIT) provided feedback on the “Carbon Tax Discussion Paper: Phase Two” to the National Treasury, expressing support for maintaining revenue neutrality for electricity prices and incentive-based allowances, while raising concerns about the lack of reference to decreasing emissions in the 9th National GHG Inventory Report, the timing and effectiveness of increased carbon offset allowances, and the removal of the trade exposure allowance for fuel combustion emissions. SAIT also highlighted the significant increase in carbon tax rates, which could hinder investment in decarbonisation, and recommended extending existing incentives and introducing a new “Investment Allowance” for decarbonisation projects.
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SAIT Submission_Part 1 of schedule NO. 1

Dec 2, 2024

SAIT supports the proposed amendments to Part 1 of Schedule No. 1, which aim to improve tariff classification clarity and efficiency. They note a potential concern for local manufacturers due to a reduced AfCFTA import duty rate but see no major issues overall.
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Re: Annexure C Proposals For Budget 2019: Tax Administration

Nov 1, 2019

The National Treasury

We have attached the Annexure C Proposals, which have been generated by the Tax Administration Technical Work Group. Part A discusses proposed clarification or alignment, whilst Part B discusses commentary on proposed changes. We appreciate the opportunity to participate in the process and would welcome further dialogue.

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