Global Daily Tax News, South Africa Releases Regulations Governing New APA Program, (May 5, 2026)

The South African Revenue Service (SARS) has launched a consultation on several draft notices regarding the nation's new advance pricing agreement program.

The consultation concerns the following draft notices, with comments invited in writing:

• Draft notice in terms of Section 76C of the Act, prescribing the persons eligible to apply to the Commissioner for a bilateral advance pricing agreement;

• Draft notice in terms of Section 76D of the Act, prescribing the fees payable by an applicant;

• Draft notice in terms of Section 76I(b) of the Act, clarifying additional reasons that may lead to the rejection of an application for a bilateral APA;

• Draft notice in terms of Section 76J(1) of the Act, specifying the requirements on SARS officials regarding the processing of applications for APAs;

• Draft notice in terms of Section 76J(3) of the Act, prescribing matters that will be clarified in a preliminary APA; and

• Draft notice in terms of Section 76P of the Act, specifying the procedures and guidelines for the implementation and operation of the APA regime.