Rulings - South African Revenue Service

Chapter 7 (sections 75-90) of the Tax Administration Act, 2011 governs the issuing of advance rulings.

Applications for advance rulings are done through eFiling, so you have to be registered as an eFiler first.

Type of ruling	Description	Binding effect
Advance ruling	An advance ruling may be any one of the following: Binding General Ruling (BGR) Binding Private Ruling (BPR) Binding Class Ruling (BCR)	The binding effect differs per type
Binding General Ruling (BGR)	A written statement issued by a senior SARS official under section 89 regarding the interpretation or the application of a tax Act to the stated facts and circumstances	On SARS and all qualifying taxpayers
Binding Private Ruling (BPR)	A written statement issued by SARS regarding the application of a tax Act to one or more parties to a ‘proposed transaction’, in respect of that ‘transaction’	On SARS and the applicant
Binding Class Ruling (BCR)	A written statement issued by SARS regarding the application of a tax Act to a specific ‘class’ of persons in respect of a ‘proposed transaction’	On SARS and the specific ‘class’ of persons
Non-binding private opinion	Informal guidance issued by SARS in respect of the tax treatment of a particular set of facts and circumstances or ‘transaction’, but which does not have a binding effect within the meaning of section 88	None, but may be cited in proceedings involving the person to whom the opinion was issued

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