In terms of section 81(1) of the Tax Administration Act, 2011, the Commissioner for the South African Revenue Service, may determine application and cost recovery fees for binding private rulings and binding class rulings issued under the advance tax ruling system. These fees are set out below:
Small, medium and micro enterprises (SMME)
Any other taxpayer
Cost recovery fees:
Cost recovery fees will be charged at R650 per hour for all non-urgent applications. A fee of R1 000 per hour will be charged for all urgent applications.
Estimated fee range
Estimation deposit (20% of higher amount)
R10000 to R35000
R35000 to R70000
R70000 to R105000
In addition to the above, any direct costs incurred in connection with an application will be recovered. These will however be subject to prior written approval being obtained from the applicant.
Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.