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Tax Administration Act, 2011 (Act No. 28 of 2011)

Chapter 7 : Advance Rulings

84. Rulings rendered void


(1) A "binding private ruling" or "binding class ruling" is void ab initio if—
(a) the "proposed transaction" as described in the ruling is materially different from the "transaction" actually carried out;
(b) there is fraud, misrepresentation or non-disclosure of a material fact; or
(c) an assumption made or condition imposed by SARS is not satisfied or carried out.


(2) For purposes of this section, a fact described in subsection (1) is considered material if it would have resulted in a different ruling had SARS been aware of it when the original ruling was made.