The South African Revenue Service (SARS) has issued INTERPRETATION NOTE 15 (Issue 6) on 30 August 2024. This Note provides guidance on the considerations that a senior SARS official will take into account when exercising a discretion to extend the prescribed period for lodging an objection under section 104(4) or an appeal under section 107(2).
A taxpayer who is aggrieved –
- by an assessment made in respect of the taxpayer; or
- by certain decisions made under the TA Act or tax Acts.
may object to and appeal against those assessments or decisions. An objection against an assessment or decision must be lodged in the manner, under the terms and within the period prescribed in the rules.
A person whose objection has been disallowed may appeal to the tax board or tax court against that outcome and in such event the appeal must be lodged in the manner, under the terms and within the periods prescribed in the TA Act and the rules.
A senior SARS official may, within prescribed limits, extend the period prescribed in the rules within which an objection or appeal must be lodged if satisfied that reasonable grounds exist for the delay.
