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South Africa: VAT relief for zero-rated goods (COVID-19)

South Africa: VAT relief for zero-rated goods, COVID-19

The South African Revenue Service (SARS) has issued guidance concerning value added tax (VAT) rules in response to the coronavirus (COVID-19) pandemic.


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In general, when the zero-rate is applied to the exportation of goods, the supplying vendor is required to obtain documentary proof to substantiate the application of the zero-rate. There are prescribed time periods within which the movable goods must be exported and the documentation in support of the export must be obtained. Non-compliance with these prescribed time periods will require the supplying vendor to account for VAT at the standard rate on the supply of the goods exported, unless beyond the control of the vendor.

Binding General Ruling 52 (BGR52)—issued on 26 March 2020—confirms that SARS considers the current COVID-19 situation to be “beyond the control of the vendor, qualifying purchaser, or the person duly authorised to represent the qualifying person” and officially extends the prescribed periods within which to export the goods by an additional three months.

  • By implication this means that the period within which to obtain the required documentation is also extended by three months.
  • The ruling only applies to supplies of movable goods for which the periods have not yet been exceeded at the date of issue of BGR52. Further, BGR52 will apply until it is withdrawn, amended or the relevant legislation is amended.
  • When VAT was charged at the standard rate on an indirect export, BGR52 provides an extension of the period within which the “qualifying purchaser” may apply for a refund of VAT.
  • For any scenario falling outside the scope of BGR52, a VAT ruling or VAT class ruling may be applied for from SARS.

Read a March 2020 report [PDF 103 KB] prepared by the KPMG member firm in South Africa

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