Administration of Estates Act, 1965
R 385
Tax Administration Act, 2011 (Act No. 28 of 2011)Chapter 7 : Advance Rulings84. Rulings rendered void |
| (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. |
