The SAIT VAT Technical WG submission (12 September 2025) provides comments on the Draft Taxation Laws Amendment Bill and Draft Tax Administration Laws Amendment Bill, focusing on technical VAT issues: it supports allowing debit/credit notes in going concern transfers but requests broader accommodation; agrees with expanding intermediary rules to local suppliers but recommends retrospective or earlier application and clearer liability rules; supports extending zero-rating rules for silver exports and for testing services to non-resident clients, while urging clearer definitions and safeguards; calls for tightening the VAT definition of “insurance” to align with the Insurance Act and avoid abuse; notes no major concerns on temporary letting of residential properties but suggests industry consultation; warns that exempting schools from VAT may create administrative burdens, economic distortions, and windfalls for affluent schools, recommending exemptions from adjustments and anti-avoidance rules; raises concerns that narrowing the zero-rating for housing programmes could harm the rental stock market; questions amendments limiting interest on VAT refunds as an added hurdle; and welcomes the VAT modernisation project but stresses the need for industry consultation before rollout.
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