Treasury invites technical tax proposals for 2020 Budget

Tuesday, November 5, 2019

The National Treasury has called on the public to submit technical tax proposals to be considered for possible inclusion in the 2020 Budget Review.

The proposals, the Department said in a statement on Monday, should be technical and not of policy nature.

Among those urged to make submissions are taxpayers and tax practitioners.

“The technical tax proposals requested in this invitation must be limited to unintended anomalies, revenue leakages, loopholes and technical matters applicable to the current tax legislation that require correction.

“Tax proposals of a policy nature are dealt with through a different process, and hence this request does not apply to tax policy proposals,” said the Treasury.

The requested technical proposals should be submitted by 25 November 2019.

“Workshops will be held with stakeholders on 4 and 5 December 2019 in order to clarify issues raised in the submitted technical proposals, and to further assist in the prioritisation of the issues raised as well as to obtain further information,” read the statement.

The dates for the workshops will be confirmed by electronic invitation to tax payers, tax practitioners and members of the public.

The department therefore urged that correct e-mail addresses and contact information are included in the written submissions.

Following this process, Treasury and SARS will submit recommendations to Finance Minister Tito Mboweni for possible inclusion in the 2020 Budget.

“It should be noted that engagement or request for more information on any proposal before the 2020 Budget is no indicator that the proposal will be included in the 2020 Budget Review.

“The final decision to include any proposal is the sole prerogative of the Minister of Finance, in consultation with all key relevant stakeholders, and no further correspondence will be entered into regarding the Minister’s response to the proposals received,” the Treasury said.

Written submissions should be sent to: and/or (Adele Collins)  

Treasury said to ensure that the technical tax proposals are in line with the criteria set for Annexure C of the Budget Review, submitted technical proposals must be within the current tax policy framework and should not result in a change of currently prevailing policy and should not have significant revenue impact.

“Technical proposals should be limited in number and be prioritised as only the most pertinent issues and concerns will be considered for inclusion in Annexure C of the 2020 Budget Review,” reads the statement.

To ensure proper assessment, technical tax proposals should be submitted under the following headings:

(i) income tax – individuals, employment and savings;

(ii) income tax – domestic business;

(iii) income tax – international;

(iv) other taxes – for example, value added tax, mineral and petroleum resource royalties; and

(v) tax administration legislation.

Each technical tax proposal must be explained in detail with the explanation covering the following areas:

(i) the legal nature of the problem

(ii) a detailed factual description of the affected transaction; and

(iii) the nature of the business / persons impacted. –