n Business Tax and Company Law Quarterly - The granting of interest-free credit : its impact on the entitlement to deduct input tax

Volume 7, Issue 3
  • ISSN : 2219-1585


Entities that are registered for value-added tax (VAT) purposes are entitled to the deduct the VAT they incur on the acquisition of goods or services as input tax if such goods or services are acquired wholly for the purpose of making taxable supplies. Where the goods or services are acquired partly for the purpose of making taxable supplies, the VAT may be deducted only to the extent that they are acquired for such purpose. The South African Revenue Service (SARS) contends in certain instances that the provision of interest-free credit comprises a financial service as defined, which is exempt from VAT. SARS then takes the view that the entity that grants the interest-free credit makes both taxable and exempt supplies, and is accordingly required to apportion the VAT incurred on its expenses. This article considers the VAT status of interest-free credit in the context of the Value-Added Tax Act 89 of 1991 (the VAT Act) and concludes that the granting of interest-free credit is a taxable supply made for no consideration, and does not result in the supplier being required to apportion the VAT incurred on expenses and acquisitions.

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