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Is the provision of therapy services for children with autism an exempt supply?

09 March 2015   (0 Comments)
Posted by: Author: SAIT Technical
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Author: SAIT Technical

Q: My client has a close corporation and the nature of the business is "therapy for children with autism”. 

I have heard that training or education of persons with a permanent physical or mental impairment is an exempt supply. Is this true?

A: For purposes of section 12 of the Value Added Tax Act, supply of educational services by the following entities is exempt from VAT:

All State schools or schools registered under the South African Schools Act, 1996 or a further education and training institution registered under the Further Education and Training Act, 1998. 

Universities, universities of technologies (previously known as technikons), colleges and other institutions providing higher education which are registered under the Higher Education Act, 1997.

Institutions which are approved Public Benefit Organisations (PBOs) in terms of section 30 of the Income Tax Act which supply any of the following –

  • adult basic education and training (ABET); 
  • education and training of religious or social workers ; 
  • educating and training of persons with permanent physical or mental impairment; or 
  • bridging courses to indigent persons to enable them to enter a higher education institution. 


The supply of those services will only be exempt from VAT in as far as the entity that renders those services is registered as a "public benefit organisation” in terms of s 30 of the Income Tax Act.

Disclaimer: Nothing in this query and answer should be construed as constituting tax advice or a tax opinion. An expert should be consulted for advice based on the facts and circumstances of each transaction/case. Even though great care has been taken to ensure the accuracy of the answer, SAIT do not accept any responsibility for consequences of decisions taken based on this query and answer. It remains your own responsibility to consult the relevant primary resources when taking a decision.


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.


The Act requires that a minimum academic and practical requirments be set to register with a controlling body. Click here for the minimum requirements of SAIT.

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