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Do invoices issued prior to VAT registration have to include a VAT number on them?

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

Q: A VAT vendor registered in August 2014 and claimed startup costs prior to registration, do invoices for startup costs from before vendor registration have to have vendor VAT registration number on them?

A: Section 18(4) of the VAT Act allows for pre-trade expenses to be deducted as calculated in terms of that provision. However in our view this provision does not override the input tax requirements in section 16(2)(a)  of the VAT Act that requires any invoice to comply with Section 20 of the VAT Act, the latter which requires the recipients VAT number to indicated on the tax invoice. In our view the vendor should apply to SARS in terms of section 20(7) of the VAT Act for a directive that the tax invoices for the re trade period does not have to have the recipients VAT number on.

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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