The SAIT submission provides commentary on Draft Binding General Ruling 4 (Issue 4), which addresses the apportionment methodology municipalities must apply to determine the VAT input tax deduction on mixed expenses as per section 17(1). SAIT highlights several technical concerns, including the incorrect reference to E11 instead of E9, the distortive impact of including gross debtor interest, the treatment of non-dividend profit share from joint ventures, the impracticality of requiring rulings for first-time dividend receipts, and inconsistencies in the treatment of forex gains and traffic fines in the apportionment formula. The submission also raises concerns about vague requirements and transitional rule dates, recommending clarity and proportionality in the final ruling.
