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2025 Legal and Policy

Legal and Policy - 27 November 2025

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SARS

  • 20 November 2025 – Customs and Excise Act, 1964

· Draft amendments to Part 1 of Schedule No. 1

Due date for comment: 5 December 2025

  • 20 November 2025 – In this issue, we provide essential updates to help you navigate the months ahead. You will find important reminders about the trust tax-return deadline (ITR12T submissions are due by 19 January 2026) and the upcoming second provisional tax payment on 28 February 2026. We also introduce a streamlined, biometric-enabled process for updating your eFiling security contact details — ideal for those experiencing challenges with OTPs. This edition also covers the latest e@syFile™ Employer release notes, new VAT regulations for foreign suppliers, changes to third-party appointments for admin penalties, and updated requirements for section 18A receipts. You will also find a video on managing outstanding tax debt, as well as news on South Africa’s exit from the FATF grey list — a significant achievement for our financial system. Finally, we provide links to the latest SARS annual and strategic reports for those interested in a deeper understanding of recent developments.
  • 21 November 2025 – SARS wishes to announce an important change regarding the processing of eCommerce import declarations by SARS. This measure is designed to ensure compliance with customs legislation, prevent misuse of the simplified import process, and support efficient processing at Compliance Centres.

Therefore, effective from 18h00 on 20 November 2025, SARS implemented a new automated validation and rejection rule for import declarations submitted by private individuals using Customs Code 70707070. If the cumulative value of imports under this code exceeds R150,000 per calendar year, any further declarations will be automatically rejected.

Key Points:

· Private individuals may import goods using Customs Code 70707070 up to a total value of R150,000 per year.

· Once this threshold is reached, additional declarations under this code will be rejected by the system.

· The individual must first apply electronically for a formal Customs Code and thereafter submit a new declaration for the affected shipment.

For more information, see the letter to stakeholders.

  • 21 November 2025 – Income Tax Act, 1962

· Table 3 – Rates at which interest-free or low interest loans are subject to income tax

  • 24 November 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.

  • 24 November 2025 — The South African Revenue Service (SARS) has formally launched the Large Business Forum (Forum), bringing together some of the country’s key taxpayers from various sectors. The entire Large & International Business Segment (L&IB) collectively contributed R600 billion in the 2024-2025 financial year. This Forum represents the first of many that will be held across all Large Business taxpayers and forms part of an extension of our enhanced service engagement. The Forum is part of SARS’ strategic intent to foster voluntary compliance and strengthen the relationship with South Africa’s largest corporate taxpayers. By establishing this platform, SARS aligns with international best practice, prioritising proactive engagement and collaboration with major corporations. SARS’ approach centres on clarity, certainty, and simplicity. The organisation works closely with large businesses to make compliance straightforward, while managing risk and tackling non-compliance.

Through the process of segmentation, SARS provides a differentiated and customised service offering that responds to the unique needs of these taxpayers. The nature of engagement also takes into account the unique compliance risks of a particular sector. It also provides similar superior service to other categories of taxpayers where there are similar circumstances. At the core of SARS’ engagement with large businesses is cooperation. SARS works side by side with these companies, following a relationship model, to ensure clear lines of communication and swift resolution of issues through a Relationship Executive. By establishing predictable points of contact, SARS enables businesses in this fast-changing digital environment the opportunity to address concerns quickly and efficiently. Given the complexity of corporate tax matters, SARS works closely with these corporations and their tax advisers to simplify and find solutions to tax related challenges. This collaboration deepens understanding, builds trust, and strengthens the partnership between SARS, businesses, and their advisers.

Ms Natasha Singh L&IB Head spoke of a triangle that anchors the relationship with large business, which comprises of citizens, clients and colleagues. She said the “dynamic interaction between these three key role players all converges, to foster voluntary compliance that helps to build a capable state for the benefit of citizens, while responding expeditiously to the needs of business and supported by an agile diverse and engaged workforce”. This commitment to partnership is captured succinctly by SARS Commissioner Edward Kieswetter, who said: “True tax compliance is not necessarily enforced but regarded within the understanding that the fiscal resources that tax provides facilitate economic enablement and social services – in particular to the most vulnerable. Compliance is voluntary when earned through mutual trust, professionalism, ethical engagement, and genuine partnership.” By working together with our largest contributors and their advisers, we build a tax system that is not only robust, but also fair and responsive to the needs of our nation”. He added that this philosophy guides SARS’s approach, which puts cooperation, open communication, and mutual respect at the heart of its relationship with large businesses and their advisers.

The Large Business Forum aims to:

· Enable the sharing of perspectives and challenges through sector-focused forums;

· Help the LB&I gain deeper insights into the economic, commercial and global pressures affecting large businesses;

· Assess the effectiveness and efficiency of the LB&I service offering;

· Share SARS concerns regarding compliance risks, aggressive tax planning and illicit activities;

· Provide thought leadership on practical implications of tax reforms; and

· Strengthen relationships between SARS and large businesses.

“Simply, the Forum creates a space where SARS and leading taxpayers can solve challenges together, share insights, and drive innovation. This partnership enhances the integrity of our tax system, supports business growth, and contributes to South Africa’s fiscal stability for the benefit of all stakeholders” said Mr. Kieswetter. The Forum will have terms of reference and will take a decision on the frequency of meetings and how the business of the Forum will be conducted. For further information, please contact SARSMedia@sars.gov.za.

For more information, see TT-GEN-01-G01 – Administration of Turnover Tax – External Guide.

· Tariff code 4909 is exempt from ITAC import permit control.

· Binding Private Ruling 422 – Lump sum from a foreign fund

· Binding Private Ruling 421 – Withdrawal from a superannuation fund situated outside South Africa

  • 26 November 2025 – Income Tax Act, 1962

· Draft Interpretation Note – Loan, advance, or credit granted to a trust by a connected natural person

Due date for comment: 16 January 2026

  • 26 November 2025 – Tax Administration Act, 2011

· Inhlakanipho Consultants (Pty) Ltd v CSARS (A333/2024) [2025] ZAGPPHC 1210 (25 November 2025)

Tax Administration Act 28 of 2011 – Parties bound by agreement entered into lawfully – agreement represented the final agreed position between the parties – intention of the parties can be ascertained from the agreement – intention was a settlement of the appellant’s liabilities of the specified periods – confidence in agreements entered with SARS and its abiding with the terms of those agreements is paramount – appeal upheld.

NATIONAL TREASURY

OECD

ATAF

SAFLII

AuthorLegal and Policy
DivisionTax
Categories
Legal and Policy
Date27 November 2025