FSA Submission to SARS on Diesel Refund Proposals
along with its members were invited to attend a "Forestry Specific"
Workshop at the SARS offices in Pretoria on 22 August 2018 to discuss
issues surrounding the diesel tax refund.
It was a productive meeting in that that Industry was able to engage
directly with SARS officials on (a) concerns that the Industry had with
their new proposals and (b), clarifying the various issues with them
relating to the operational charaterstics of the
find attatched FSA's Submission to SARS flowing from the items
discussed at the abovementioned meeting - the third such Submission
made. I have also attached our previous
two Submissions as Annexures A & B. Please note that this
submission is based on an Industry perspective. The FSA members who
attended the meeting were all invited to make their own individual
Of importance to note is that our FSA submission motivates and gives recommendations on the following main points raised:
- Definitions as to various aspects of what constitutes "primary production" in the Forestry Industry context - of particular
importance being those related to:
- what constitutes primary production;
- where does primary production end in terms of the value chain; and
- which "qualifying" activities should be included for the purposes of a diesel tax refund.
- An overview of the:
obligations imposed by Government on the Sector;
- outsourcing, contracting and partnership arrangements presently operational in the Sector; and
- other arrangments specific to the Sector.
- How small-scale timber growers could be assisted to benefit from the diesel tax refund system.
recommendations made, it is hoped that SARS will not only put in place a
system to benefit small-scale-timber growers but will also allow the
following activities to be deemed to be qualifying activities
(which, under the current proposals, they are not):
- Any "off-site" transport, most importantly, long-haul transport of timber to mills
and empty return trips from mills
- Transport of wattle bark
- Transport of biomass
- Activities carried out by labour carrier vehicles
- Activities carried out by "Forest Protection" vehicles
Should SARS adopt
the recommendations made by FSA, this could potentially save the
Industry many millions of Rands per year in its diesel fuel bill.