[Section 18A heading substituted by section 31 of the Revenue Laws Amendment Act, 2007 (Act No. 35 of 2007)]
| (1) |
Notwithstanding the provisions of section 23, there shall be allowed to be deducted in the determination of the taxable income of any taxpayer so much of the sum of any bona fide donations by the taxpayer in cash or of property made in kind which was actually paid or transferred during the year of assessment to— |
[Words preceding section 18A(1)(a) substituted by section 22 of the Taxation Laws Amendment Act, 2019 (Act No. 34 of 2019), GG 42951, dated 15 January 2020]
| (i) |
public benefit organisation contemplated in paragraph (a)(i) of the definition of "public benefit organization" in section 30(1) approved by the Commissioner under section 30; or |
which—
| (aa) |
carries on in the Republic any public benefit activity contemplated in Part II of the Ninth Schedule, or any other activity determined from time to time by the Minister by notice in the Gazette for the purposes of this section; |
| (bb) |
complies with the requirements contemplated in subsection (1C), if applicable, and any additional requirements prescribed by the Minister in terms of subsection (1A); and |
| (cc) |
has been approved by the Commissioner for the purposes of this section; |
[Section 18A(1)(a) substituted by section 31 of the Taxation Laws Amendment Act, 2017 (Act No. 17 of 2017)]
| (b) |
any public benefit organisation contemplated in paragraph (a)(i) of the definition of "public benefit organization" in section 30(1) approved by the Commissioner under section 30, which provides funds or assets to any public benefit organisation, institution, board or body contemplated in paragraph (a), or any department contemplated in paragraph (c) and which has been approved by the Commissioner for the purposes of this section; or |
[Section 18A(1)(b) substituted by section 4(a) of the Tax Administration Laws Amendment Act, 2020 (Act No. 24 of 2020), GG44080, dated 20 January 2021]
| (i) |
any agency contemplated in the definition of "specialized agencies" in section 1 of the Convention on the Privileges and Immunities of the Specialized Agencies, 1947, set out in Schedule 4 to the Diplomatic Immunities and Privileges Act, 2001 (Act No. 37 of 2001); |
| (ii) |
the United Nations Development Programme (UNDP); |
| (iii) |
the United Nations Children's Fund (UNICEF); |
| (iv) |
the United Nations High Commissioner for Refugees (UNHCR); |
| (v) |
the United Nations Population Fund (UNFPA); |
| (vi) |
the United Nations Office on Drugs and Crime (UNODC); |
| (vii) |
the United Nations Environmental Programme (UNEP); |
| (viii) |
the United Nations Entity for Gender, Equality and the Empowerment of Women (UN Women); |
| (ix) |
the International Organisation for Migration (IOM); |
| (x) |
the Joint United Nations Programme on HIV/AIDS (UNAIDS); |
| (xi) |
the Office of the High Commissioner for Human Rights (OHCHR); or |
| (xii) |
the United Nations Office for the Coordination of Humanitarian Affairs (OCHA), |
if that agency, programme, fund, High Commissioner, office, entity or organisation—
| (aa) |
carries on in the Republic any public benefit activity contemplated in Part II of the Ninth Schedule, or any other activity determined from time to time by the Minister by notice in the Gazette for the purposes of this section; |
| (bb) |
furnishes the Commissioner with a written undertaking that such agency will comply with the provisions of this section; |
| (cc) |
waives diplomatic immunity for the purposes of subsection (5)(i); and |
| (dd) |
has been approved by the Commissioner for the purposes of this section; or |
[Section 18A(1)(bA)(dd) inserted by section 4(b) of the Tax Administration Laws Amendment Act, 2020 (Act No. 24 of 2020), GG44080, dated 20 January 2021]
| (c) |
any department of government of the Republic in the national, provincial or local sphere as contemplated in section 10(1)(a), which has been approved by the Commissioner for the purposes of this section, to be used for purpose of any activity contemplated in Part II of the Ninth Schedule, |
[Section 18A(1)(c) and words following substituted by section 4(c) of the Tax Administration Laws Amendment Act, 2020 (Act No. 24 of 2020), GG44080, dated 20 January 2021]
as does not exceed—
(a).png)
in which formula:
| (AA) |
"A" represents the amount to be determined; |
| (BB) |
"B" represents the average value of the aggregate of all of the participatory interests held by investors in the portfolio for the year of assessment, determined by using the aggregate value of all of the participatory interests in the portfolio at the end of each day during that year; or |
[Section 18A(1)(c)(B) substituted by section 35(1)(a) of the Taxation Laws Amendment Act, 2018 (Act No. 23 of 2018), GG 42172, dated 17 January 2019 - deemed to have come into operation on 1 March 2018 (section 35(2)]
Provided that any amount of a donation made as contemplated in this subsection and which has been disallowed solely by reason of the fact that it exceeds the amount of the deduction allowable in respect of the year of assessment shall be carried forward and shall, for the purposes of this section, be deemed to be a donation actually paid or transferred in the next succeeding year of assessment.
[Proviso to section 18A(1)(c)(B) inserted by section 52(1)(c) of the Taxation Laws Amendment Act, 2013 (Act No. 31 of 2013) - effective 1 March 2014]
| (1A) |
The Minister may, by regulation, prescribe additional requirements with which a public benefit organisation, institution, board or body or the development carrying on any specific public benefit activity identified by the Minister in the regulations, must comply before any donation made to that public benefit organisation, institution, board or body or the department shall be allowed as a deduction under subsection (1). |
[Section 18A(1A) substituted by section 37(1)(b) of the Taxation Laws Amendment Act, 2010 (Act No. 7 of 2010)]
| (1B) |
Any activity determined by the Minister in terms of subsection (1)(a) or any requirements prescribed by the Minister in terms of subsection (1A), must be tabled in Parliament within a period of 12 months after the date of publication by the Minister of that activity or those requirements, as the case may be, in the Gazette, for incorporation into this Act. |
[Section 18A(1B) inserted by section 20(e) of the Taxation Laws Amendment Act, 2002 (Act No. 30 of 2002)]
| (1C) |
The constitution or founding document of a public benefit organisation carrying on the activity contemplated in paragraph 4(d) of Part II of the Ninth Schedule, must expressly provide that the organisation— |
[Words preceding section 18A(1C)(a) substituted by section 16(e) of the Revenue Laws Amendment Act, 2006 (Act No. 20 of 2006)]
| (a) |
may not issue any receipt contemplated in subsection (2) in respect of any donation made by a person to that public benefit organisation, unless— |
| (i) |
that donation is made by that person on or after 1 August 2002; and |
[Section 18A(1C)(a)(i) substituted by section 37(1)(c) of the Taxation Laws Amendment Act, 2010 (Act No. 7 of 2010)]
| (ii) |
that person (in the case of a company, together with any other company in the same group of companies as that company) has during the relevant year of assessment of that person donated an amount of at least R1 million to that organisation; |
| (b) |
must ensure that every donation contemplated in paragraph (a), in respect of which such a receipt has been issued, will be matched by a donation to that organisation of the same amount made by a person who is not a resident and which is made from funds generated and held outside the Republic; and |
| (c) |
must utilise the amount of— |
| (i) |
all donations contemplated in paragraph (a), in respect of which such a receipt has been issued, and all income derived therefrom, in the Republic in carrying on that activity; and |
| (ii) |
all donations contemplated in paragraph (b), either in the Republic in carrying on that activity, or in respect of a transfrontier conservation area of which the Republic forms part. |
| (2) |
Any claim for a deduction in respect of any donation under subsection (1) shall not be allowed unless supported by— |
| (a) |
a receipt issued by the public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation or the department concerned, containing— |
[Words preceding section 18A(2)(a)(i) substituted by section 35(1)(b) of the Taxation Laws Amendment Act, 2018 (Act No. 23 of 2018), GG 42172, dated 17 January 2019 - deemed to have come into operation on 1 March 2017 (section 35(3)]
| (i) |
the reference number of the public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation or the department issued by the Commissioner for the purposes of this section; |
[Section 18A(2)(a)(i) substituted by section 35(1)(c) of the Taxation Laws Amendment Act, 2018 (Act No. 23 of 2018), GG 42172, dated 17 January 2019)
| (ii) |
the date of the receipt of the donation; |
| (iii) |
the name of the public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation or the department which received the donation, together with an address to which enquiries may be directed in connection therewith; |
[Section 18A(2)(a)(iii) substituted by section 35(1)(c) of the Taxation Laws Amendment Act, 2018 (Act No. 23 of 2018), GG 42172, dated 17 January 2019)
| (iv) |
the name and address of the donor; |
| (v) |
the amount of the donation or the nature of the donation (if not made in cash); |
| (vi) |
a certification to the effect that the receipt is issued for the purposes of section 18A of the Income Tax Act, 1962, and that the donation has been or will be used exclusively for the object of the public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation concerned or, in the case of a department in carrying on the relevant public benefit activity; and |
[Section 18A(2)(a)(vi) substituted by section 35(1)(c) of the Taxation Laws Amendment Act, 2018 (Act No. 23 of 2018), GG 42172, dated 17 January 2019)
| (vii) |
such further information as the Commissioner may prescribe by public notice; or |
[Section 18A(2)(a)(vii) inserted by section 2 of the Tax Administration Laws Amendment Act, 2021 (Act No. 21 of 2021), Notice No. 771, GG45788, dated 19 January 2022]
| (b) |
an employees’ tax certificate as defined in the Fourth Schedule on which the amount of donations contemplated in paragraph 2(4)(f) of that Schedule, for which the employer has received a receipt contemplated in paragraph (a), is given. |
| (2A) |
A public benefit organisation, institution, board, body or department may only issue a receipt contemplated in subsection (2) in respect of any donation to the extent that— |
[Words preceding section 18A(2A)(a) substituted by section 37(1)(e) of the Taxation Laws Amendment Act, 2010 (Act No. 7 of 2010)]
| (a) |
in the case of a public benefit organisation, institution, board or body contemplated in subsection (1)(a) which carries on activities contemplated in Parts I and II of the Ninth Schedule, that donation will be utilised solely in carrying on activities contemplated in Part II of the Ninth Schedule; |
[Section 18A(2A)(a) substituted by section 26(1)(d) of the Revenue Laws Amendment Act, 2005 (Act No. 31 of 2005)]
| (b) |
in the case of a public benefit organisation contemplated in subsection (1)(b)— |
| (i) |
that organisation will within 12 months after the end of the relevant year of assessment distribute or incur the obligation to distribute at least 50 per cent of all funds received by way of donation during that year in respect of which receipts were issued: |
[Words preceding the proviso to section 18A(2A)(b)(i) substituted by section 29(1)(a) of the Taxation Laws Amendment Act, 2014 (Act No. 43 of 2014) - effective 1 March 2015)]
Provided that the Commissioner may, upon good cause shown and subject to such conditions as he or she may determine, either generally or in a particular instance, waive, defer or reduce the obligation to distribute any funds, having regard to the public interest and the purpose for which the relevant organisation wishes to accumulate those funds; and
| (ii) |
which provides funds or assets to public benefit organisations, institutions, boards or bodies or any department that carry on public benefit activities contemplated in Parts I and II of the Ninth Schedule, that donation will be utilised solely to provide funds or assets to a public benefit organisation, institution, board or body contemplated in subsection (1)(a), which will utilise those funds or assets solely in carrying on activities contemplated in Part II of the Ninth Schedule or to any department contemplated in subsection (1)(c) which will utilise those funds or assets solely for the purpose of any activity contemplated in Part II of the Ninth Schedule; or |
[Section 18A(2A)(b)(ii) substituted by section 4(d) of the Tax Administration Laws Amendment Act, 2020 (Act No. 24 of 2020), GG44080, dated 20 January 2021]
| (c) |
in the case of a department, that donation will be utilised solely in carrying on activities contemplated in Part II of the Ninth Schedule. |
[Section 18A(2A)(c) substituted by section 37(1)(f) of the Taxation Laws Amendment Act, 2010 (Act No. 7 of 2010)]
| (2B) |
A public benefit organisation, institution, board or body contemplated in subsection (2A), must obtain and retain an audit certificate confirming that all donations received or accrued in that year in respect of which receipts were issued in terms of subsection (2), were utilised in the manner contemplated in subsection (2A). |
[Section 18A(2B) substituted by section 6(1) of the Taxation Laws Second Amendment Act, 2008 (Act No. 4 of 2008)]
| (2C) |
The Accounting Authority contemplated in the Public Finance Management Act for the department which issued any receipts in terms of subsection (2), must on an annual basis submit an audit certificate to the Commissioner confirming that all donations received or accrued in the year in respect of which receipts were so issued were utilised in the manner contemplated in subsection (2A). |
[Section 18A(2C) substituted by section 52(1)(d) of the Taxation Laws Amendment Act, 2013 (Act No. 31 of 2013)]
| (2D) |
Any public benefit organisation contemplated in subsection (1)(b), in respect of any amount that is not distributed as required by subsection (2A)(b)(i), shall distribute or incur the obligation to distribute all amounts received in respect of investment assets held by it, other than amounts received in respect of disposals of those investment assets to any public benefit organisation, institution, board or body contemplated in subsection (1)(a) or to any department contemplated in subsection (1)(c), no later than six months after— |
[Words preceding section 18A(2D)(a) substituted by section 4(e) of the Tax Administration Laws Amendment Act, 2020 (Act No. 24 of 2020), GG44080, dated 20 January 2021]
| (a) |
every five years from the date on which the Commissioner issued a reference number referred to in subsection (2)(a)(i) to that public benefit organisation referred to in subsection (1)(b), if that public benefit organisation is incorporated, formed or established on or after 1 March 2015; or |
| (b) |
every five years from 1 March 2015, if that public benefit organisation referred to in subsection (1)(b) was incorporated, formed or established and issued with a reference number referred to in subsection (2)(a)(i) prior to 1 March 2015. |
[Section 18A(2D) inserted by section 29(1)(b) of the Taxation Laws Amendment Act, 2014 (Act No. 43 of 2014) - effective 1 March 2015]
| (3) |
If any deduction is claimed by any taxpayer under the provisions of subsection (1) in respect of any donation of property in kind, other than immovable property of a capital nature where the lower of market value or municipal value exceeds cost, the amount of such deduction shall be deemed to be an amount equal to— |
[Words preceding section 18A(3)(a) substituted by section 52(1)(3) of the Taxation Laws Amendment Act, 2013 (Act No. 31 of 2013) - effective 1 March 2014]
| (a) |
where such property constitutes— |
| (i) |
a financial instrument which is trading stock of the taxpayer, the lower of fair market value of that financial instrument on the date of that donation or the amount which has been taken into account for the purposes of section 22(8)(C); or |
[Section 18A(3)(a)(i) substituted by section 37(1)(h) of the Taxation Laws Amendment Act, 2010 (Act No. 7 of 2010)]
| (ii) |
any other trading stock of the taxpayer (including any livestock or produce in respect of which the provisions of paragraph 11 of the First Schedule are applicable), the amount which has been taken into account for the purposes of section 22(8)(C) or, in the case of such livestock or produce, the said paragraph 11, in relation to the donation of such property; or |
[Section 18A(3)(a)(ii) substituted by section 37(1)(h) of the Taxation Laws Amendment Act, 2010 (Act No. 7 of 2010)]
| (b) |
where such property (other than trading stock) constitutes an asset used by the taxpayer for the purposes of his trade, the lower of – |
| (i) |
the fair market value of that property on the date of that donation; or |
| (ii) |
the cost to the taxpayer of such property less any allowance (other than any investment allowance) allowed to be deducted from the income of the taxpayer under the provisions of this Act in respect of that asset; or |
[Section 18A(3)(b)(ii) substituted by section 34(1)(l) of the Revenue Laws Amendment Act, 2003 (Act No. 45 of 2003)]
| (c) |
where such property does not constitute trading stock of the taxpayer or an asset used by him for the purposes of his trade, the lower of— |
| (i) |
the fair market value of that property on the date of that donation; or |
| (ii) |
the cost to the taxpayer of such asset, less, in the case of a movable asset which has deteriorated in condition by reason of use or other causes, a depreciation allowance calculated in the manner contemplated in section 8(5)(bB)(i); or |
[Section 18A(3)(c) substituted by section 34(1)(l) of the Revenue Laws Amendment Act, 2003 (Act No. 45 of 2003)]
| (d) |
where such property is purchased, manufactured, erected, assembled, installed or constructed by or on behalf of the taxpayer in order to form the subject of the said donation, the lower of— |
| (i) |
the fair market value of that property on the date of that donation; or |
| (ii) |
the cost to the taxpayer of such property. |
[Section 18A(3)(d) substituted by section 34(1)(l) of the Revenue Laws Amendment Act, 2003 (Act No. 45 of 2003)]
| (3A) |
If any deduction is claimed by any taxpayer under the provisions of subsection (1) in respect of any donation of immovable property of a capital nature where the lower of market value or municipal value exceeds cost, the amount of such deduction shall be determined in accordance with the formula: |
.png)
in which formula:
| (a) |
‘A’ represents the amount deductible in respect of subsection (1); |
| (b) |
‘B’ represents the cost of the immovable property being donated; |
| (c) |
‘C’ represents the amount of a capital gain (if any), that would have been determined in terms of the Eighth Schedule had the immovable property been disposed of for an amount equal to the lower of market value or municipal value on the day the donation is made; and |
[Section 18A(3A)(c) substituted by section 22 of the Taxation Laws Amendment Act, 2020 (Act No. 23 of 2020), GG44083, dated 20 January 2021]
| (d) |
‘D’ represents 60 per cent in the case of a natural person or special trust or 20 per cent in any other case. |
[Section 18A(3A)(d) substituted by section 35(1)(d) of the Taxation Laws Amendment Act, 2018 (Act No. 23 of 2018), GG 42172, dated 17 January 2019]
| (3B) |
No deduction shall be allowed under this section in respect of the donation of any property in kind which constitutes, or is subject to any fiduciary right, usufruct or other similar right, or which constitutes an intangible asset or financial instrument, unless that financial instrument is— |
[Section 18A(3B)(b) substituted by section 35(1)(e) of the Taxation Laws Amendment Act, 2018 (Act No. 23 of 2018), GG 42172, dated 17 January 2019 - deemed to have come into operation on 1 April 2018 (section 35(4)]
| (4) |
The provisions of section 30(10) shall apply mutatis mutandis in respect of any institution, board or body contemplated in subsection (1)(a). |
[Section 18A(4) substituted by section 3 of the Tax Administration Laws Amendment Act, 2014 (Act No. 44 of 2014)]
| (5) |
If the Commissioner has reasonable grounds for believing that any person who is in a fiduciary capacity responsible for the management or control of the income or assets of any public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation(other than an institution, board or body in respect of which subsection (5B) applies) has— |
| (a) |
in any material way failed to ensure that the objects for which the public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation was established are carried out or has expended moneys belonging to the public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation for purposes not covered by such objects; |
| (b) |
issued or allowed a receipt to be issued to any taxpayer for the purposes of this section in respect of any fees or other emoluments payable to that organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation by that taxpayer; |
| (c) |
issued or allowed a receipt to be issued in contravention of subsection (2A) or utilised a donation in respect of which a receipt was issued for any purpose other than the purpose contemplated in that subsection; |
| (d) |
failed to obtain and retain an audit certificate as contemplated in subsection (2B); or |
| (e) |
failed to submit an audit certificate as contemplated in subsection (2C), |
[Section 18A(5)(d)(e) inserted by section 4(f) of the Tax Administration Laws Amendment Act, 2020 (Act No. 24 of 2020), GG44080, dated 20 January 2021]
the Commissioner may by notice in writing addressed to that person direct that–
| (i) |
any donation in respect of which a receipt was issued by that public benefit organization, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation during any year of assessment specified in that notice, will be deemed to be taxable income of that public benefit organization, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation in that year; and |
| (ii) |
if corrective steps are not taken by that public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation within a period stated by the Commissioner in that notice, any receipt issued by that public benefit organisation, institution, board, body or agency, programme, fund, High Commissioner, office, entity or organisation in respect of any donation made on or after the date specified in that notice shall not qualify as a valid receipt for purposes of subsection (2); |
[Section 18A(5) substituted by section 35(1)(f) of the Taxation Laws Amendment Act, 2018 (Act No. 23 of 2018), GG 42172, dated 17 January 2019]
| (5A) |
If the Commissioner has reasonable grounds for believing that any regulating or co-ordinating body of a group of public benefit organisations, institutions, boards or bodies contemplated in section 30(3A) or subsection (6) fails to— |
| (a) |
take any steps contemplated in section 30(3A) or subsection (6), to exercise control over any public benefit organization, institution, boards or bodies in that group; or |
| (b) |
notify the Commissioner where it becomes aware of any material failure by any public benefit organization, institution, board or body over which it exercises control to comply with any provision of this section, |
the Commissioner may by notice in writing addressed to that regulating or co-ordinating body direct that if corrective steps are not taken by that regulating or co-ordinating body within a period stated by the Commissioner in that notice, any receipt issued by public benefit organisations, institutions, boards or bodies in that group in respect of any donation made on or after the date specified in that notice shall not qualify as a valid receipt for purposes of subsection (2).
[Section 18A(5A) substituted by section 26(1)(f) of the Revenue Laws Amendment Act, 2005 (Act No. 31 of 2005) - effective 1 April 2006]
| (5B) |
If the Commissioner has reasonable grounds for believing that any accounting officer or accounting authority contemplated in the Public Finance Management Act or an accounting officer contemplated in the Local Government: Municipal Finance Management Act, 2003 (Act No. 56 of 2003), as the case may be, for any institution in respect of which that Act applies, has issued or allowed a receipt to be issued in contravention of subsection (2A) or utilised a donation in respect of which a receipt was issued for any purpose other than the purpose contemplated in that subsection, the Commissioner— |
[Words preceding section 18A(5B)(a) substituted by section 52(1)(h) of the Taxation Laws Amendment Act, 2013 (Act No. 31 of 2013)]
| (a) |
must notify the National Treasury and the Provincial Treasury (if applicable) of the contravention; and |
| (b) |
may by notice in writing addressed to that accounting officer or accounting authority direct that, if corrective steps are not taken by that accounting officer or accounting authority within a period stated by the Commissioner in that notice, any receipt issued by that institution in respect of any donation made on or after the date specified in that notice shall not qualify as a valid receipt for purposes of subsection (2). |
[Section 18A(5B)(b) inserted by section 26(1)(g) of the Revenue Laws Amendment Act, 2005 (Act No. 31 of 2005)]
| (5C) |
If any public benefit organisation contemplated in subsection (1)(b), has not distributed amounts as contemplated in subsection (2D), or has not incurred the obligation to distribute those amounts received in respect of investment assets held by it, those amounts shall be deemed to be taxable income of that public benefit organisation in that year of assessment. |
[Section 18A(5C) substituted by section 34 of the Taxation Laws Amendment Act, 2015 (Act No. 25 of 2015)]
| (6) |
The Commissioner may, for the purposes of this section, approve a group of institutions, boards or bodies contemplated in subsection (1)(a)(ii), sharing a common purpose which carry on any public benefit activity under the direction or supervision of a regulating or co-ordinating body, where that body takes such steps, as prescribed by the Commissioner, to exercise control over those institutions, boards or bodies in order to ensure that they comply with the provisions of this section. |
[Section 18A(6) inserted by section 20(f) of the Taxation Laws Amendment Act, 2002 (Act No. 30 of 2002)]
| (i) |
in a fiduciary capacity responsible for the management or control of the income and assets of any public benefit organisation, institution, board or body contemplated in this section; or |
| (ii) |
the accounting officer or accounting authority contemplated in the Public Finance Management Act or the Local Government: Municipal Finance Management Act, 2003 (Act No. 56 of 2003), as the case may be, for any institution in respect of which that Act applies, |
[Section 18A(7)(ii) substituted by section 52(1)(i) of the Taxation Laws Amendment Act, 2013 (Act No. 31 of 2013)]
who intentionally fails to comply with any provisions of this section, or a provision of the constitution, will or other written instrument under which such organisation is established to the extent that it relates to the provisions of this section, shall be guilty of an offence and liable on conviction to a fine or to imprisonment for a period not exceeding 24 months.
[Section 18A(7) inserted by section 7 of the Tax Administration Laws Amendment Act, 2012 (Act No. 21 of 2012)]
Stamp Duties Act, 1968 (Act 77 of 1968)
