South Africa: Vendor Can Appeal Unrequested Apportionment Method Ruling, Supreme Court of Appeal Decides

Vendor may appeal a ruling allowing use of an alternative apportionment method not requested by the vendor
Supreme Court of Appeal decision on July 8, 2025
Right to appeal under section 32(1)(a)(iv) of the VAT Act
Case: Commissioner for South African Revenue Service v. African Bank Limited
Vendors must apply for a ruling to use an alternative method if standard methods are not equitable
Section 32(1)(a)(iv) allows appeal if SARS refuses a method
SARS argued approval of an alternative method prevents appeal
Court rejected SARS’ interpretation, supporting vendor’s right to appeal

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.