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Carl's Tax Blog

A generally jaundiced and cynical news feed regarding the nonsense our revenue authorities get up to. Hopefully it will entertain and inform, all at the same time. And for free too!

When tax maths gets really tricky...

posted 14 Jul 2011, 13:15 by Carl Nielsen

Here's an interesting fact that I recently discovered. I was submitting a VAT return and getting very annoyed with the new "improved" (in fact, "modernised" as SARS puts it) efiling VAT form. You see, for some obscure reason, you are required on your VAT return to reflect your inclusive-of-VAT turnover, as well as the VAT amount that is included therein. On the wonderful old form, it was possible to only enter the latter and the form was programmed to work out the former. Wonderful.

The new form insists that you enter the turnover figure and it calculates the VAT from that. Now, as any VAT vendor knows, you calculate the VAT amount from an inclusive-of-VAT amount by applying the so-called "VAT fraction" which is, based on the current VAT rate of 14%, 14/114. My annoyance stemmed from the fact that the form was getting this calculation wrong! For a while I thought either I was going mad (well, I was probably doing the return in the middle of the night, so it could well have just been fatigue) or my calculator was failing me. In the end, I confirmed that it was indeed the efiling system mucking it up.

A query to a fairly helpful chap at SARS led me to discover that the reason for the differences was rounding errors caused by the system applying, instead of the VAT fraction of 14/114, a fraction of 0.1228 (which is 14/114 but rounded off to 4 decimals). Annoyed, I resigned myself to having to use the "adjustment" entry on the VAT form to correct the mess.

I was therefore quite amazed to discover more recently that the use of the 0.1228 fraction by the SARS website is actually legislated. The VAT Act actually has a special section that specifies that the VAT fraction should be rounded to 5 decimal places (as it happens 14/114 = 0.12280, so based on 14% it actually only needs 4).  I can only assume that 14/114 is maths too complicated for the idiots who write our laws. The interesting effect of this is that, by law, a vendor is required to pay over less VAT than it has collected from its customers. As an example:

A (large) vendor charges R100m + VAT for a contract. He therefore collects R14m in VAT. When it comes time to pay this over, his calculation of what to pay is R114m X 0.1228 = R13,999,200. Okay, so on a deal worth R100m, R800 isn't a lot, but multiply it out across the economy and that's a fair whack of cash that SARS is giving back to vendors.

Of course the bad news is that every single accounting package out there does know maths, and calculates the VAT correctly. So more than likely the differences on the VAT return will just cause differences in the accounts that will have to be rectified - something that probably costs more in wasted time and effort than the few rands the rounding saves. Even when the law is bizarrely stupid in your favour, its most likely to do it in a way that is just plain annoying.

Why we should hate SARS

posted 16 Jun 2011, 00:55 by Carl Nielsen

Here's an article I just read in SAICA's Tax Newsletter, courtesy of Ernst & Young. I'm probably breaking all sorts of copyright rules posting it here, but hopefully no-one will notice.

Importers using accredited importing agents can sleep well at night in the knowledge that all VAT issues relating to importation are well under control, as the accommodating importing agent has taken care of it. Business as usual, with VAT being claimed once a valid tax invoice is received from the clearing agent. Or so it would seem…

Even though a valid tax invoice is generally acceptable to substantiate the claim of input tax in respect of expenses incurred in the course or furtherance of a vendor’s enterprise, this is not the case with VAT incurred on imports. The VAT Act requires the vendor to obtain and retain the relevant bill of entry as well as the receipt for the payment of VAT on importation, before an input tax deduction is permissible in this respect. Unfortunately, most importers are unaware of this requirement and claim input tax based on the tax invoice received from the clearing agent. Consequently there may be a timing difference between when the input tax was claimed (the invoice date) and the date the vendor is entitled to claim the input tax (the date the clearing agent pays SARS).

This problem is exacerbated when the clearing agent makes use of the so-called deferment scheme, i.e. it only pays the VAT on importation 30 days after the goods have been cleared for home consumption (the bill of entry date). In many instances, the vendor might not even be aware of the fact that the clearing agent is using a deferment scheme and that VAT had not been paid over at the date the clearing agent issued the invoice, resulting in a potentially costly tax exposure.

SARS has recently started to raise assessments where vendors claim input tax in respect of imported goods before the VAT has been paid over to SARS by the clearing agent, and to levy penalties and interest. Depending on the level of imports, this amount may be quite significant. To mitigate the risk, importers should request clearing agents to supply proof of the VAT on importation being paid, before the related input tax is deducted.

Although there is ultimately no VAT loss to the fiscus, SARS is chasing the penalties and interest on these timing differences. Also important to note is that SARS will raise assessments for a period of five years, despite the fact that the vendor might have been subjected to VAT refund audits on a regular basis.

Am I the only person who thinks that the authorities set us up to fail so that they can charge penalties?


How the new Companies Act affects CC's

posted 9 May 2011, 05:33 by Carl Nielsen

Well, the rabble at the Department of Trade & Industry managed finally to drag Zuma out of bed, slap a pen in his hand and get him to sign the necessary bit of paper to bring into force the new dispensation under which companies in South Africa are governed. "Hang on," I hear you say, "I trade in a CC not a Company... what's that got to do with me". Well, I'm afraid the new law impacts CC's as well... read on.

As you may recall, the powers that be originally decided that enough was enough, they're sick of allowing people to trade with limited liability without decent regulation (i.e. in a CC) and they announced the death of the CC. A public outcry duly ensued, and the tune was changed: existing CC's would live on (Viva!) but no new ones could be formed. Whew, we all breathed a sigh of relief and the Shelf Company/CC businesses all went ballistic registering Shelf CC's by the score so that although no new CC's can be formed, we can all still probably buy unused CC's for the next 20 years.

Ah ha, but what we didn't realise was those lawmakers can be quite crafty. They might have relented and let CC's live on, but they never really intended this to be in more than just "in name". Already the new provisions that apply to Companies are starting to be made applicable to CC's after all. Basically they're saying: "What we said all along was that there would be no point in have an entity called a CC because a small company will serve just as well, so now we're going to make it that a small company and a CC are much the same thing".

Okay, I haven't completely got my mind around what the difference will ultimately be between a CC and a company, but for now CC's do actually live on much as they did. Except (and that's quite big except... should probably have made it bold), the exemption from audit for a CC is no longer automatic (do I hear some boot-quaking).

The new rules are basically that if your CC is big and important then you must be audited. Here's how it works.

Give yourself 1 point for each person you employ
Give yourself 1 point for each R1m you owe third parties at your year end
1 point for each R1m of turnover
1 point for each person who has a beneficial interest in the CC (for a CC, probably just the members, unless there's a trust involved)

Right, now if you have more than 350 point, prepare to be audited. If you have between 100 and 350, and you draw up your own financial statements, you have to be audited too. If an independent outsider does your AFS for you, then you're off the hook. If you're below 100 then things stay much as they are (phew!)

The rules are much the same for companies, except that in the 100 to 350 arena, you have to be "Independently Reviewed" which is another way of saying "Sort of audited". Below 100 I think there are still cases where a Review is required (I think this is where the shareholders are not also all directors).

Apologies for the vagueness. When it comes time to evaluate this for each of my clients, I'll make sure I know exactly how it works... but for now I thought I'd just keep you all posted.

Companies and CCs

posted 10 Mar 2011, 08:08 by Carl Nielsen

It has been a while since you've heard from me. I guess I've been busy, and there has been no major news worth reporting. However, I thought I'd just send a quick message regarding some changes that are coming up.

From 1 April, the new Companies Act that has been in the offing for quite a number of years now comes into force. Bureaucracy being what it is, the passage to life of the Act has been an interesting one with laws being made subject to promulgation only on announcement by some minister or other, only to be changed before the minister got around to promulgating them. This has meant anyone actually learning the law as it has been enacted has wasted a great deal of time and brainpower. Cunningly I have employed the ostrich approach to the whole thing. However, the whole shebang is now coming to life from 1 April and hence I've started to take notice.

Anyway, probably the issue of most interest to you is what will happen with CC's. I have had a few people ask, intimate or even categorically state that CC's must be converted to companies and/or that new ones cannot any longer be set up. Well, on the first point 100% wrong and on the second point right, but only from 1 April. So, you can set up a CC before 1 April, but from then on, you're forced to go the Company route. I suspect, however, that the shelf company/CC purveyors, realising how much South Africans love CCs, are going berzerk registering shelf CCs which will probably mean that starting a business in an unused CC will be possible for quite some time yet.

You might be wondering on what basis they decided to shut down CCs. The main point is that they reckon a small owner-managed company under the new system will look much the same as an old CC under the old. They're presumably right and I guess over the next while we'll see how it all pans out. It seems that an entity with no real public interest won't need to be audited, putting it on a par with a CC in terms of administrative headache and cost. An entity of sufficient size or public interest (I'm being deliberately vague here because I haven't yet read the specifics of the criteria) will be subjected to an "independent review", another beast whose definition I haven't quite figured out yet, but I think a fairly airy-fairy concept that won't involve nearly the same amount of in-jou-slaai-krappery as a full force audit, and therefore won't cost the earth.

The main point is that if you're thinking you might want to start a CC, then you should probably move to do so, although more than likely you'll still be able to buy a shelf CC without too much headache or cost for quite a while. Or, a company under the new rules shouldn't be much different to a CC, so as the hitchhikers guide says "Don't Panic" - just set up a company in due course.

Of further interest is that after possibly even longer than the whole companies law process has taken, SARS has finally announced the actual date that Secondary Tax on Companies will die and be replaced by Dividends Tax. A bit of background in case you don't know: STC = a tax triggered by the declaration of a dividend by a company or close corporation (or in some cases by being deemed to declare a dividend) payable by the company paying the dividend. Dividends tax is the same thing, except the recipient of the dividend is liable for the tax. However, they've made it a withholding tax, which means the company declaring the dividend still physically pays it. So it'll look very similar to STC.

The reason they decided to change it is that STC was pretty unique to South Africa, so all the dumb foreigners didn't understand it. And apparently it makes things look bad because it increases the tax rate that companies pay. So cunningly they'll shift the burden from companies to their shareholders, and wala, suddenly it looks much cheaper tax-wise to start a company in SA than it used to.

The rate of tax is unchanged, however because under STC the tax reduced the reserves of the paying company, thereby reducing the tax base of the company, the effective rate under the new system works out to about 0.9% more than before (I'll bore you with the maths proving this is you want me to). So, if your company is sitting with a bunch of undistributed reserves, and you're likely to have to distribute them sometime, then best to do it before the change and save that ~1%. The date of the change, by the way is 1 March 2012... so you've got a year to think about it.

Here's a little nugget

posted 18 Aug 2010, 10:04 by Carl Nielsen

This item will only really be of interest to bodies corporate, such as Sectional Title schemes, and there only really of impact to those rich enough to have to bother about tax in the first place.

First off, lets mention the bit that many people who should know about it, for many moons didn't know about, although it seems they mostly do now, but just in case there are any who still aren't aware, here it is again: Since time immemorial, bodies corporate have been exempt from tax on levy income they receive from their own members which is specifically used to defray the expenses of the corporate body. Since a while ago (I think about the 2009 tax year but would have to look it up to say for definite here so let me rather be vague and let you do the work if you need to) Bodies Corporate have been exempted from the first R50,000 of other income too. So that's the new bit you might have missed.

Now the bit that I missed. This time I can tell you exactly when it starts: years of assessment commencing after 1 January 2009 (so generally speaking, for years ending sometime during calendar year 2010). And the big news: such entities are no longer required to pay provisional tax whether they earn investment and other income that will ultimately be taxed or not. For them, taxation becomes an annual event.

I suspect if you have already paid provisional tax for a year that you didn't need to, you'll have a devil of a time getting SARS to refund it to you. And you'd probably have an even worse time getting them to pay interest on it. Both those options are probably strictly available, but good luck if you try. Rather write to SARS now telling them to "get stuffed regarding future provisional tax" (well, maybe be a little polite... difficult, I know) and let whatever you've paid in the meantime go to settle that final liability on assessment.

The latest on PAYE

posted 6 Aug 2010, 01:40 by Carl Nielsen   [ updated 6 Aug 2010, 01:43 ]

As you have probably heard, maybe from me in one of my previous communications, our ultra-efficient Revenue Collection Service thinks it is a wonderful idea to register everyone for tax, even if they'll never in a million years pay tax. They made out to employers as if they'd have to submit income tax numbers for all their employees on the next PAYE reconciliation. Proactive employers therefore told their employees: you'd better go and get registered. Said employees did so, only to be turned away by SARS on the grounds that they don't need to be registered. Which in some cases was true, but not necessarily. Let's cut to the chase here: chaos kind of limply reigned.

So here comes the next communication from SARS: please stop sending your employees to us. If they don't have a tax number you can leave it out on the next return. We'll issue them a number. Wonderful!

(Can you imagine how many people will end up with 2 tax numbers now. Theoretically SARS should be able to distinguish by ID number, but that kind of places some reliance on Home Affairs and we all know how efficient that organisation is).

Prediction: more chaos.

But, the key thing to note for now is that if you are an employer, you can stop threatening your staff with wet noodle whippings or whatever else you might have over them if they don't come up with a tax number. If you're an employee, don't worry yet: SARS will issue you with a tax number in due course if you don't already have one - lucky you! If you're a tax practitioner, practice a knowing smile combined with a grimace, because there might be lots of work (some scary no doubt) coming your way... erm, I guess that's me.

A correction and something on timing - 02/07/2010

posted 3 Aug 2010, 01:26 by Carl Nielsen

Thanks to Lawrence for pointing out a small but vital error in my last
communication... just shows you shouldn't do these things in t'middle o' the
night.

The correction is to the very first line where I said that the opening of
tax season means that individuals can NOT submit their returns. That was
meant to say they can NOW submit their returns!

And a question from a client as to the timing for provisional taxpayers. It
is correct that the return is only due by 31 January: if you miss that
deadline SARS is entitled to charge penalties. However, if you owe any tax,
SARS can start charging interest from 1 October. So, if you anticipate a
liability and want to avoid the interest, then even though the return can be
delayed, you must make a payment by 30 September. This is the monster
previously known as the "topping up payment". There is a proposal that this
situation will start to apply to everyone (currently it only applies to
provisional taxpayers) and in fact, the change is even in the law and has
been for a while. But the lawmakers, in their wisdom, made it subject to an
announcement of the starting date by the minister of finance, and as far as
I am aware, Pravin hasn't bothered to do that yet.

Tax deadlines and medical expenses - 01/07/2010

posted 3 Aug 2010, 01:22 by Carl Nielsen   [ updated 3 Aug 2010, 01:24 ]

The big news from SARS today is that Tax Season 2010 is open. This means
that individuals are now able to submit their tax returns. Deadline for
non-provisional taxpayers is 26 November 2010 and for provisional taxpayers
is 31 January 2011.

A new requirement announced has prompted me to briefly mention medical
expenses, one of the last few things that can help to reduce tax. One of the
great benefits of being poor has always been that you pay less tax. The good
news is that if you're poor and sick you're on an even better wicket.

Seriously, and with apologies for my crude sense of humor, medical expenses
are tax-deductible and especially for middle to lower income earners can
give tax savings.

How the tax deductions for medical expenses work is a bit complex, but let
me explain the basics: a portion of contributions to a medical aid fund
(calculated based on a per month rand value based on the number of
beneficiaries covered by your medical aid) is tax deductible (or a tax-free
fringe benefit if your employer pays it for you). The rest of your medical
aid contributions, together with you medical expenses are deductible to the
extent that they exceed 7.5% of your taxable income: sort of like an excess
system. So, keep a record of your expenses if they start to add up. The
deductible ones are basically:
 - doctor and doctor-ish consultation and service fees and
 - prescribed medicines.

If your medical aid covers any of the costs, even out of your medical
savings, those aren't deductible (the good news regarding medical savings is
that your contributions to the medical savings are treated the same as
medical aid premiums).

If you are over 65, the 7.5% excess falls away. So all your medical expenses
are deductible.

If you are handicapped or have a handicapped member of your family, you also
don't worry about the 7.5%. This is the bit that has changed this year:
well, not a change in the law, just that SARS wants everyone in this boat to
re-register by filling in a form which their doctor also needs to sign. I've
popped the form on my website (www.dfs.co.za) if anyone needs it.

Note that you can claim for all medical expenses that you pay, even if not
for you. So, generally it makes sense in a family for one person to be the
designated-medical-expense-payer. The person with the higher income stands
to gain a higher benefit due to saving tax at a higher rate, whereas the
person earning less will start saving earlier due to the 7.5% threshold. So
you might want to do some sums to decide whose money it actually was that
went to pay the doc. If you're over 65 or have a handicapped family member:
definitely best for the higher earner to pay things.

How cars are taxed or untaxed

posted 3 Aug 2010, 01:20 by Carl Nielsen   [ updated 3 Aug 2010, 01:22 ]

As promised, some details on changes in taxes around motor vehicles, and an
attempt at a synopsis on how it all works, which I hope you'll find useful.

The question of how cars are taxed can be divided into 2 broad categories
based on who owns the vehicle: the employer or the employee. For those of
you who are sole proprietors, in respect of your own vehicle, this question
perhaps has no meaning but it is answered for you: you may do things as if
it is an employer-owned vehicle. We'll deal with that situation first, often
referred to as a company car.

COMPANY CARS

The company car provision kicks in where you're an employer owns a vehicle
which it lets its employee use. In this case, the default situation is that
the employer is entitled to claim as a tax-deduction all the costs involved
in running the vehicle including a wear & tear allowance and including
finance charges should the vehicle be financed, or lease payments should it
be leased. The employee, subject to certain exceptions, is taxed on what is
called a fringe benefit, calculated at 2.5% per month of the value of the
vehicle (the value is a defined thing in terms of the law, but basically
boils down most of the time to the cost of the vehicle excluding VAT). 2.5%
per month multiplies out to 30% per year, which is pretty significant and so
it kinda sucks. If the same employee is given a second vehicle, e.g. a
director given a vehicle for his wife, or indeed a 3rd, 4th, 5th... vehicle,
the percentage is 4%: pretty huge.

A small adjustment can be made reducing the fringe benefit where the
employee is required to pay in for petrol or maintenance, but it is minor
and not worth bothering about. Far more interesting are the situations
whereby you can get out of the fringe benefit altogether. These are premised
on the fact that the fringe benefit is intended to put a value on the
*private use* of the vehicle. So, if there is no private use, there is no
value and the benefit falls away. The only way that this can be achieved is
to prevent the private use of the vehicle. Most obviously, if the vehicle
stays at the business premises so that the employee is required to use his
own transport to get to and from work and for his personal travel. A
sneakier option is to implement a policy whereby employees are forbidden
from using the vehicle for private use. They must sign acknowledgement of
this, and the policy must be genuine, policed and implemented (i.e. not a
sham) or SARS will ignore it.

The situation regarding company cars is touted to change, I believe from 1
March 2011. The revisions are two-fold:

First, the rate that will apply is now 4% for the first vehicle, and I
believe the same for the rest (I might be wrong here: I can't remember if
they said they were considering increasing the rate for additional vehicles.
Quite likely I guess!)

Second, there will be a way to reduce the taxable benefit to the extent that
the vehicle is actually used for business. This will require a logbook of
business travel, and if I remember correctly an apportionment of the rand
value of the fringe benefit will then be made on the basis of the ratio of
business to private travel. So, if you actually use the vehicle 80% of the
time (or of the kilometers actually!) for business, only 20% of the fringe
benefit will ultimately be taxed. In terms of the monthly PAYE tax for
employees, the proposal is that only 80% of the 4% will be taxed then, the
balance to be taxed on assessment: allowing a bit of a buffer for the
potential business travel deduction.

Oh, I just remembered: there is a third leg to the proposal: they want to
bring VAT into the vehicle cost as well as the cost of a maintenance plan.
So that fringe benefit value is just looking higher and higher!!!

TRAVEL ALLOWANCES

The second broad category is where an employee owns his own vehicle. In this
case, we are already living under the new dispensation: it kicked in from 1
March.

The changes since 1 March are pretty small, but with far-reaching effect. So
what I'll do is sketch the old system and then the understanding of the new
system will be pretty straight-forward (as much as these things ever are!)

So, on the old system, the idea was that the costs of the vehicle, being
privately owned, were borne by the employee not the company. To the extent
that the vehicle was used for legitimate business however, it was fair that
this should be paid by the employer without penalising the employee. Hence,
a tax-free payment by the employer to the company to cover that cost is
reasonable. In terms of the tax law there are 2 ways to do this and then a
combination of them both. In practice, employers might make payments with
reference to specific costs (e.g. paying employees petrol or maintenance for
them) - especially popular when the employee in question is a member or
director of the CC/company - but these schemes generally slot into the ways
that the taxman recognises somehow.

The 2 options basically are: reimbursive or "the rest". Under a
reimbursement scheme, the employee keeps a track of business km travelled
and is reimbursed at a rate per km for those km. For purposes of calculating
PAYE, these amounts never have tax deducted. However, if the rate exceeds
R2.90 per km or the total km's in a year exceeds 8000 or the employee is
getting any other allowance for his vehicle costs (including, for example
the company paying his petrol) then the reimbursements are subject to tax on
assessment. However, the employee might get some deductions against them and
we'll get that.

"The rest" option usually takes the form of a set monthly "travel allowance"
often done on a salary sacrifice or package basis (i.e. it's actually salary
by another name). However, payments of fuel and maintenance for the employee
would also fall into this scheme. And as mentioned, if reimbursements exceed
the limits mentioned above, they'll also get considered under this category.
A set month travel allowance is subject to PAYE. I seem to think payment of
fuel etc is also subject to PAYE. If anyone seeks specific advice on this,
I'll look it up for you. Up to 28 Feb 2010, only 60% of the amount was
subject to PAYE so as to provide a buffer for a probably expense claim on
assessment. The full amount would be taxable on assessment after the
taxpayer has determined the amount that he can deduct.

Regarding that deduction, the idea is to work out the cost of using the
vehicle for business purposes. This is calculated by the formula: business
km X rate per km. Up to Feb 2010, there were 2 ways of calculating each
component of the formula
   Business km: (a) keep a log book OR (b) assume the first 18000km are
private, the next 14000km are business and the rest are private.
   Rate per km: (a) keep a record of your expenses and divide by total km OR
(b) use a formula supplied by SARS

This is the point where I can mention the change. Basically, option (b) on
the calculation of business km is scrapped. You now must keep a logbook
record in order to get a benefit. Also, anticipating fewer people
legitimately qualifying for the benefit, and simultaneously improving cash
flow, SARS went ahead and increase the PAYE component to be applicable to
80% of a fixed allowance.

SUMMARY

So what does this all mean. Well, for those in receipt of travel allowance
(except a reimbursive allowance less than the limits I mentioned) you MUST
now keep a logbook of your travel. I guess those being reimbursed are
already having to do so, cos how else would they know how much reimbursement to
get. And, for now, those with company cars don't need to bother, but from next
year, the tax on your company car will be a bit crazy but with the option to
reduce it by... keeping a logbook.

Finally then, what is a logbook. Well, it ain't defined so the line I take
is that it needs to provide sufficient detail to achieve what it sets out to
do, and that is to distinguish business and private travel. Hence, I believe
that a record of just business travel is sufficient (then the private travel
is the balancing figure). The log should record each trip, who it was to,
where they are, what the opening and closing mileage on the odometer was
before and after and from that, the mileage actually travelled. SARS has a
logbook available for download. I'll try to get a copy and put it on my
website (www.dfs.co.za).

Signing off then, with a last word: errors and omissions excepted! I hope
everything I've said is right, but with tax you can never be sure.

Changes in PAYE reconciliation process - 21/06/2010

posted 3 Aug 2010, 01:19 by Carl Nielsen

This message is for those of you who are employers. SARS has implemented new
procedures in respect of the reconciliation of PAYE, SDL and UIF. In
particular, they now expect us to reconcile twice a year. The first such
reconciliation will cover the 6 months to August 2010, and will probably be
due in October. SARS has decided to go the rather time-intensive route of
requiring that everyone who is employed be registered as a taxpayer and
issued with a tax number whether they earn sufficient to pay tax or not: the
reconciliation process will insist on a tax number for every person
included. My understanding is that as part of the recon process, we will be
able to register those not yet registered, however, it will be helpful to be
proactive about this. For those of you who use our payroll services, please
can you start to find out from your staff what their tax numbers are if you
have not already provided that information to me. If they don't have tax
numbers, it would be good if they can try to register themselves with SARS
especially if they earn more than R60K per year or receive any allowances
(as they are liable to be registered already).

To register with SARS I believe a payslip, a copy of ID and a bank statement
or cancelled cheque or letter from the bank together with an IT77 form
(downloadable from www.dfs.co.za I hope) should suffice. In the unlikely
event that the individual has no bank account, I guess an affidavit
confirming that fact is what SARS would want.

I know I promised some information on travel allowances and haven't
delivered it yet. Since promising it, more changes have been mooted by
treasury, which I need to take into account in my communication. I'll try to
get to it sooner rather than later.

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