204.    Procedure for compromise of tax debt

 

(1)     To ‘compromise’ a tax debt, a senior SARS official and the ‘debtor’ must sign an agreement setting out-

 

(a)     the amount payable by the ‘debtor’ in full satisfaction of the debt;

 

(b)     the undertaking by SARS not to pursue recovery of the balance of the tax debt; and

 

(c)     the conditions subject to which the tax debt is ‘compromised’ by SARS.

 

(2)     The conditions referred to in subsection (1)(c) may include a requirement that the ‘debtor’ must-

 

(a)     comply with subsequent obligations imposed in terms of a tax Act;

 

(b)     pay the tax debt in the manner prescribed by SARS; or

 

(c)     give up specified existing or future tax benefits, such as carryovers of losses, deductions, credits and rebates.