The South African Institute of Taxation (SAIT) presented comprehensive feedback on the 2024 Draft Taxation and Administration Laws Amendment Bills, highlighting several key concerns. These included practical challenges with proposed changes to the input VAT prescription period, the unbalanced treatment of currency losses under section 24I, and the risk of double taxation from anti-avoidance trust amendments. SAIT supported changes around public officer appointments but raised concerns about the risks faced by default appointees. The submission questioned allowing non-legal practitioners to represent taxpayers in Tax Court without clear “fit and proper” criteria and advocated for moving the ADR process earlier while ensuring independence. Additional comments addressed insufficient relief for unlisted real estate funds, confusion around retrospective amendments to fuel legislation, and the need for collaboration rather than punishment in ETI reforms. Concerns were also raised over VAT changes affecting B2B services, electronic supplies, and education sector exemptions, with SAIT calling for improved clarity, thresholds, and consultation.
