The South African Institute of Taxation (SAIT) submitted comments on the draft DA 5 form, expressing concern that the proposed amendments do not align with existing legislation governing the declaration of sealable goods on board ships. The submission highlights discrepancies between the form and Rules 9.02 and 9.03, particularly in the unequal allocation of goods between the ship’s master and crew, which contradicts the law. SAIT also points out unclear references to excisable goods and the impracticality of certain form elements for crew members. The Institute recommends that the form be revised to ensure full legal compliance, clarity, and practicality in its application.
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