Key takeaways
- SARS issued Interpretation Note 147, "Reduced assessments: Meaning of 'readily apparent undisputed error'", on 11 November 2026. It explains section 93(1)(d) of the Tax Administration Act.
- An error qualifies only if it is both "readily apparent" and "undisputed": provable by face-value checking, simple arithmetic or comparison with an objective source such as an IT3(b) certificate or a prior assessment.
- Companies and trusts request a reduced assessment on eFiling or on form RRA02; individuals and sole proprietors use RRA01. The burden of proof sits with the taxpayer.
- An assessment issued by SARS prescribes three years after the original assessment date; IN 147's own example is an assessment dated 20 August 2023 that prescribes at the end of 19 August 2026. Self-assessments prescribe after five years.
- If your written request with supporting documents reaches SARS before prescription, SARS can still issue the reduced assessment after the deadline passes, under section 99(2)(d)(iii).
The news: SARS has written down what counts as an obvious error
Most business owners know two ways to deal with an assessment they disagree with: pay it, or object. There is a third, quieter route in section 93(1)(d) of the Tax Administration Act. If SARS is satisfied that there is a "readily apparent undisputed error" in an assessment it issued, or in a return you filed, it can issue a reduced assessment. No objection, no dispute process, no notice of appeal.
The provision has been in the Act for years. The phrase "readily apparent" was added by the Tax Administration Laws Amendment Act of 2015, effective 8 January 2016. What was missing was SARS's own reading of what those words mean in practice. On 11 November 2026 it published that reading as Interpretation Note 147, which appeared on the What's New at SARS page the same day.
SARS describes the route as "a less formal, cost-effective mechanism". It also makes clear what the route is not: it "does not replace the dispute resolution process" under Chapter 9 of the Act, and it is not a way to reopen a matter you and SARS disagree on.
For a small business that means a cheaper fix for a genuine slip, provided you can show it is a slip and you get the request in on time.
"Readily apparent" and "undisputed" are two separate tests
IN 147 is firm that both words have to be satisfied. Fail either and the request is rejected.
Readily apparent means the error can be seen without a deep investigation. The note gives three ways SARS will check:
- Verification at face value: the number on the assessment does not match the number on the document.
- Simple arithmetic: the figures do not add up.
- Comparison with an objective source: an IT3(b) certificate, a prior assessment, a donation receipt.
The examples in the note make the line clearer. Medical expenses of R5,000 on an assessment against R50,000 on the medical scheme certificate is readily apparent. A section 18A donation receipt keyed in as R500 instead of R5,000 is readily apparent. An omitted deduction counts as an "error" too, because an omission is still a mistake in the return.
By contrast, a company that wanted its assets reclassified, and needed a stack of records to prove the new classification, was turned down. In SARS's words, an error that needs "voluminous" documents or "a more detailed investigation" is not readily apparent.
Undisputed means there is no argument about the facts or the law. If you and SARS read a section differently, or SARS questions the underlying transaction, the matter belongs in the objection process. IN 147 also says an event in a later year, such as a contract cancelled after the return was filed, is not an error in the original return at all.
One point helps businesses in particular. The note says an error by a taxpayer in a return "must be interpreted to include an error that originates in the records that are used to complete the return". If the wrong figure came from your books, it can still qualify, as long as the correct figure is easy to prove.
The real deadline is prescription, and some 2023 assessments are close
IN 147 sets no separate time limit for a section 93(1)(d) request. The only limit is prescription under section 99(1) of the Act:
- An assessment issued by SARS prescribes three years after the date of the original assessment.
- A self-assessment prescribes five years after the date of the original assessment.
The note does the calculation for you. An original assessment issued on 20 August 2023 prescribes at the end of the day on 19 August 2026. Apply the same rule to today: an income tax assessment SARS issued in mid-November or December 2023 prescribes in mid-November or December 2026. If a company's 2023 assessment carries an obvious mistake against you, the window is now a matter of weeks.
The protection that matters is in section 99(2)(d)(iii). IN 147 explains that if SARS becomes aware of the error before the assessment prescribes, SARS can still make the reduced assessment afterwards, "irrespective of when SARS completes its review". SARS is treated as aware once your written request and supporting documents are submitted.
Example 8 in the note shows how tight this can be. A taxpayer's assessment was issued on 30 March 2022. On 29 March 2025, the last day of the three-year period, they found R30,000 of exempt income taxed in error and filed an RRA01 on eFiling that day. SARS only finished its review on 10 April 2025, after prescription. The reduced assessment was still allowed, because the request arrived in time.
The lesson: the date that counts is the date SARS receives a complete request, not the date SARS gets round to it.
How to make the request, step by step
If you think one of your company's assessments contains a clear error, IN 147 points to this process:
- Find the original assessment date. It is on the notice of assessment (ITA34 for individuals, the company equivalent on eFiling). Add three years for an assessment SARS issued.
- Check the error passes both tests. Can you prove it with one or two documents, a sum, or a certificate? Does SARS have any reason to dispute the facts or the law? If the answer to the second question is yes, prepare an objection instead.
- Gather the proof. The burden sits with you under section 102(1), on the civil standard: "more probable than not". Attach the certificate, receipt, ledger extract or prior assessment that shows the right figure.
- Submit the request. Use eFiling, or form RRA02 for companies and trusts and RRA01 for individuals and sole proprietors. IN 147 lists [email protected] for tax practitioners and [email protected] for taxpayers without a practitioner where a manual form is used.
- Keep proof of the submission date. If prescription is close, the eFiling acknowledgement is what protects you.
- Watch for SARS's response. SARS may accept the request, ask for more documents, or reject it with reasons. If it is rejected, you can still go the objection and appeal route, as long as those periods have not run out.
That last condition is the trap. The note says section 93(1)(d) "must not be regarded as an alternative for formal disputes where a taxpayer has exceeded the prescribed periods for objection and appeal". SARS's dispute rules generally allow 80 business days to object. If there is any chance SARS will see your point as debatable, lodge the objection inside that period rather than relying on a reduced-assessment request alone.
What this means for payroll and VAT
IN 147 is written around income tax. All its examples use income tax returns and the RRA01 and RRA02 forms. But section 93 sits in the Tax Administration Act, which carries the administrative rules shared across the tax Acts SARS administers, and the note's definition of "assessment" covers both assessments by SARS and self-assessments by the taxpayer.
Two points matter for employers:
- Employer errors are a separate ground. Section 93(1)(e)(i) lets a senior SARS official reduce an assessment where it is based on an incorrect return, or a failure to submit one, by an employer. In practice, when an employee's assessment is wrong because the IRP5 was wrong, the clean fix starts with a corrected IRP5 from the employer. IN 147 mentions this ground but does not analyse it.
- VAT and PAYE are self-assessments. IN 147 notes that self-assessments prescribe after five years rather than three. It does not give a VAT201 or EMP201 example, so confirm the correct correction route for those returns with your accountant or on eFiling before you rely on section 93(1)(d).
For most SMEs the bigger point is upstream. Almost every example in IN 147 that succeeded turned on a single document that proved the right figure. Almost every one that failed needed a pile of records, or an argument. Books that reconcile to source documents turn a dispute into a request. Our bookkeeping basics guide covers the habits that make that possible.
Why we build it this way
Bluubin is built so the figure on a return can be traced back to the document behind it. Bank statements are uploaded and reconciled line by line, so the ledger matches what actually went through the account. The asset register calculates depreciation automatically, so asset classifications and write-offs have a record behind them rather than a year-end estimate. Management reports, including the P&L and balance sheet, come from the same ledger that feeds your SARS-ready VAT201 reporting.
On the payroll side, Bluubin's e@syFile integration supports the EMP201, EMP501 and IRP5 reconciliation, so the certificates your employees receive agree with what you declared. If SARS ever asks whether an error is "readily apparent", that is the trail you want.
There is a thirty-day trial with full access and no credit card if you want to run it against your own numbers.
If you take two things from this article: check the original assessment dates on your company's 2023 income tax assessments now, because an assessment issued in late 2023 prescribes in late 2026; and if one of them contains an error you can prove with a single document, submit the request on eFiling before that date and keep the acknowledgement.
This guide is general information to help you get oriented — it isn't formal tax or legal advice. Thresholds, rates and deadlines change, so confirm the current figures on the SARS website or with your accountant before you act.