SARS resets the documentary proof required to zero-rate a going-concern sale
This page records one dated change. For the rules in South Africa as they stand today, see the South Africa guide →
- Jurisdiction
- 🇿🇦 South Africa
- Tax
- VAT
- Change type
- Invoice rules
- Status
- In force
- Impact
- Action required
- Announced
- 17 July 2026
- Effective
- 17 July 2026
- Instrument
- ZA-IN31-ISSUE5-2026
- Authority
- South African Revenue Service (SARS)
- Systems
- ERP, Reporting, Tax engine
- Verified
- Fetched from official source · high confidence
South African VAT vendors making supplies zero-rated under sections 11(1) and 11(2) of the VAT Act, and in particular vendors disposing of an enterprise as a going concern.
Update going-concern sale files to retain the sale contract, the tax invoice and the recipient's VAT Notice of Registration, per Interpretation Note 31 (Issue 5).
ERPReportingTax engine
SARS issued Interpretation Note 31 (Issue 5), dated 17 July 2026, 'Documentary proof required for the zero-rating of goods or services', updating Tables A and B of acceptable documentary proof for supplies zero-rated under sections 11(1) and 11(2) of the VAT Act. For the disposal of an enterprise as a going concern, at Table A Item G, a vendor must hold a copy of the sale contract confirming that the enterprise is disposed of as a going concern and will be an income-earning activity at transfer, a tax invoice, and the recipient's VAT Notice of Registration.
What changed in detail
SARS issued Interpretation Note 31 (Issue 5), “Documentary proof required for the zero-rating of goods or services”, dated 17 July 2026. It updates Tables A and B of the documentary proof SARS accepts for supplies zero-rated under sections 11(1) and 11(2) of the VAT Act.
For the disposal of an enterprise as a going concern, at Table A Item G, a vendor must hold three documents: a copy of the sale contract confirming that the enterprise is disposed of as a going concern and will be an income-earning activity at the time of transfer, that the necessary assets are disposed of to the purchaser, and that the consideration is inclusive of VAT at the zero rate; a tax invoice; and the recipient’s VAT Notice of Registration.
What it means
Going-concern zero-rating fails on paperwork far more often than on substance, and this tightens exactly the file that gets audited. The recipient’s Notice of Registration is the item most often missing, and it is the one document the buyer holds — so it has to be collected at closing, as a condition of the sale, rather than reconstructed two years later when the assessment arrives and the counterparty has no reason to help.