The SAIT Environmental Tax Technical Work Group submitted comments on the Draft Taxation Laws Amendment Bill, 2024, focusing on proposed changes to environmental tax provisions under the Carbon Tax Act. The group recommends retaining full calorific value ranges to support accurate emissions reporting, aligning fuel values (e.g., for coal and diesel) with Department of Forestry, Fisheries and Environment (DFFE) guidelines, and including South Africa-specific emission factors. They call for clearer unit specifications in emissions tables, clarification on whether carbon offset capacity thresholds apply per project or entity, and updates to ensure cullet is excluded in glass emission factors. Finally, they urge that the Act explicitly state whether Tier 1, 2, or 3 emissions methodologies may be used and whether these must align with DFFE submissions to avoid confusion currently caused by ambiguous legislative language.
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