The South African Institute of Taxation (SAIT) submitted comments to SARS on the draft amendments to customs rules under sections 40, 41, and 120 of the Customs and Excise Act, focusing on clarifying procedures for adjusting bills of entry where transfer pricing impacts declared customs values. SAIT supports the intent to formalize these processes but raises several concerns regarding practicality, administrative burden, and timing. Key recommendations include broadening the definition of “duty” to encompass all levies under the Act, extending notification and payment periods to allow for realistic compliance, simplifying documentation requirements, and introducing clearer extension and response timelines for SARS. SAIT also urges SARS to release all supporting tools, such as the pro forma calculation spreadsheet, for comment before finalization and to streamline correction mechanisms to reduce duplication and administrative inefficiency.
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