A senior SARS official may enter into an instalment payment agreement only if—
||the taxpayer suffers from a deficiency of assets or liquidity which is reasonably certain to be remedied in the future;
||the taxpayer anticipates income or other receipts which can be used to satisfy the tax debt;
||prospects of immediate collection activity are poor or uneconomical but are likely to improve in the future;
||collection activity would be harsh in the particular case and the deferral or instalment agreement is unlikely to prejudice tax collection; or
||the taxpayer provides the security as may be required by the official.