On 25 February 2026, the Finance Minister delivered his National Budget 2026 speech, in which he addressed the following amendments to the Value-Added Tax (VAT) Act, 1991:
Services rendered to a Customs-Controlled Area Enterprise (CCAE) or Special Economic Zone (SEZ) operator
Taxpayers requested that the VAT Act, 1991, be amended to reflect the policy position on services rendered in terms of the zero-rating provisions of Section 11(2)(k) of the VAT Act, 1991. There is confusion about whether all services rendered to a CCAE or to an SEZ operator in a customs-controlled area are required to be physically rendered therein to qualify for the zero-rating.
It is proposed that Section 11(2)(k) of the VAT Act, 1991, be amended to reflect that the services must be physically rendered in the customs-controlled area to qualify for zero-rating.
Supply of gold to banks
Refineries rely on pooled contributions from various depositors to achieve the required purity and volume of gold. The input includes low-grade by-products, recycled bullion, previously manufactured gold from jewellery, coins and dental alloys. Section 11(1)(f) of the VAT Act, 1991, provides for the zero-rating of gold, in specific forms, supplied to the listed entities that have not “undergone any manufacturing process other than the refining thereof or the manufacture or production in order to achieve such specific forms”.
It is complex to trace or isolate unprocessed, primary-source gold, and the refined product will likely have both components of primary and secondary gold that have gone through the process of manufacturing. This results in suppliers not being able to comply with Section 11(1)(f) of the VAT Act, 1991, and the South African Revenue Service (SARS) must follow protracted audit procedures to confirm the validity of the application of the zero-rating.