On September 8, 2023, the South African Revenue Service (SARS) released a discussion paper presenting its vision for modernising the VAT system. Although the paper offered a comprehensive look at SARS’s strategy, some specifics are still ambiguous, making it challenging to fully understand the extent of the proposed changes.
The vision for a modernised VAT framework
The current VAT system, largely unchanged since its inception in 1991, is due for an update. SARS plans to modernise the framework in a phased approach, aiming to make the VAT system more efficient and easier to manage for both the tax authority and its vendors. A key aspect of this strategy involves real-time, or near real-time, transmission of VAT data to SARS, commonly referred to as e-invoicing.
Additionally, the paper introduces the concept of a disaggregated VAT return. This return would expand upon the current data fields and include more detailed input disclosure points. Although specifics on what the new VAT return will look like are still lacking, it is clear that change is coming.
What will the new VAT return look like?
At this point, SARS has not provided much detail on the new VAT return, leaving many questions unanswered. Will the return be industry-specific, similar to the company income tax return (ITR14 form) that customises for sectors like banking, retail, or insurance? Currently, the VAT201 form has a single line for zero-rated goods and services. Will SARS provide a more granular breakdown for the new return? Will there be a drop-down list of all possible zero-rated supplies and services?
Furthermore, the discussion paper touches on apportionment. However, it is unclear whether SARS will request a simple percentage calculation or require a more detailed breakdown of how apportionment is calculated. Will there be dedicated space on the VAT return for these calculations?
Benefits and challenges of a modern VAT return
A modernised VAT return offers benefits to both vendors and SARS. For vendors, it could simplify reconciliation before submitting returns, streamlining the entire process. For SARS, using artificial intelligence (AI) to enhance its risk engine could make tax collection more efficient and reduce fraud.
However, these benefits come with challenges.
Achieving standardisation across industries will be difficult due to the diverse nature of different sectors. Additionally, many businesses have invested heavily in systems that align with the current VAT201 form, integrating them with their ERP (Enterprise Resource Planning) software. Updating these systems will require significant time, effort, and third-party involvement.
Looking ahead
While we are eagerly anticipating further details from SARS regarding the specifics of the modern VAT return, it is evident that this initiative will have a lasting impact on the reporting of VAT in South Africa. Businesses will need to navigate potential complexities and adapt accordingly. Nevertheless, we are hopeful about the evolution of this process and are committed to actively participating in the ongoing consultations with SARS.