Tax Administration Act, 2011 (Act No. 28 of 2011)

Chapter 7 : Advance Rulings

Purchase

(1)	A "binding private ruling" or "binding class ruling" is void ab initio if—

(a)	the "proposed transaction" as described in the ruling is materially different from the "transaction" actually carried out;

(b)	there is fraud, misrepresentation or non-disclosure of a material fact; or

(c)	an assumption made or condition imposed by SARS is not satisfied or carried out.

(2)	For purposes of this section, a fact described in subsection (1) is considered material if it would have resulted in a different ruling had SARS been aware of it when the original ruling was made.