The SAIT submission on the Draft Guide issued by SARS regarding allowances and deductions for renewable energy assets welcomes the overall clarity and structure of the document but raises concerns about potential limitations in its practical application. Specifically, SAIT highlights that foundations or supporting structures integral to renewable energy systems, such as solar PV installations, should be deductible under sections 12B and 12BA if they are functionally integrated and share the same useful life as the primary asset. However, the guide appears to exclude costs related to improvements, such as structural roof reinforcements or parking lot installations, where the supporting infrastructure may still serve other purposes after asset removal. SAIT urges SARS to reconsider the narrow interpretation of eligible deductions under section 12BA to ensure the intended tax relief reaches taxpayers making qualifying renewable energy investments.

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