Global Daily Tax News, South Africa Guides On Reportable Tax Arrangement Rules, (Nov 10, 2025)

The South African Revenue Service has released a new guide on the obligation, included in Sections 34 to 39 of the Tax Administration Act, to report arrangements that might lead to an "undue tax benefit" or that are designed to avoid or postpone tax liabilities.

The reporting obligation is intended to ensure that SARS is able to better monitor and review these arrangements, to prevent aggressive tax avoidance.

Reporting must be done within 45 business days of the arrangement being reportable or 45 business days of a person becoming a "participant" in an existing "reportable arrangement".

The new guidance outlines the definitions, criteria, exclusions, disclosure requirements, promoter obligations, enforcement powers, and penalties associated with "reportable arrangements". The guidance includes practical examples and tax authority insights.