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How do I report a reportable arrangement to SARS using RA01?
How do I report a reportable arrangement to SARS using RA01?
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Direct answer
SARS says a participant in a reportable arrangement who derives, or will derive, a tax benefit must report it within 45 business days after the arrangement becomes reportable or after becoming a participant in an existing reportable arrangement. A participant need not report if it obtains a written statement from another participant that the arrangement has been disclosed. SARS says a further 45 business days may be granted where reasonable grounds for extension exist.
What this means in practice
SARS's guide says sections 34 to 39 of the Tax Administration Act govern reportable arrangements. It describes transactions or schemes that taxpayers may be required to disclose. Record arrangement documents, parties, implementation dates, relevant tax facts and the date from which the 45-business-day period is measured. The filing team should work from this controlled record, not from a short transaction description.
Step-by-step
- Preserve the arrangement documents, implementation timeline, participant list and adviser material.
- Obtain a technical assessment of whether the arrangement is reportable. Legislation prevails where it conflicts with the guide.
- Identify each participant and establish who will report. If relying on another participant's disclosure, obtain the written statement that SARS requires.
- Calculate the relevant 45-business-day date and keep the calculation with the filing record. Raise a potential extension request promptly where there are reasonable grounds.
- Prepare the current RA01 disclosure using a checked factual schedule. Reconcile names, tax references, dates and transaction descriptions to the evidence.
- Submit through the current SARS process available to the authorised person. Save the acknowledgement, final submitted information and case reference.
- Preserve the submission record and manage any SARS correspondence through the designated team.
Documents and records to keep
- Arrangement documents and implementation timeline.
- Participant list and written statement where another participant disclosed.
- RA01 workpapers, final filing copy, confirmation and correspondence.
- Due-date calculation and any extension request.
- Governance records showing review and submission approval.
Important limits and exceptions
Whether an arrangement is reportable is fact and law dependent. This procedural guide cannot replace a technical opinion. Do not assume a promoter's role removes a taxpayer's responsibility. If another participant made the disclosure, retain the specific written statement. An extension is not automatic.
When to get tailored advice
Take tailored advice where the arrangement has cross-border features, multiple participants, a promoter, confidentiality conditions or a possible missed deadline. Escalate if facts change after submission or another participant will not provide written confirmation.