7.    Conflict of interest

 

The Commissioner or a SARS official may not exercise a power or become involved in a matter pertaining to the administration of a tax Act, if-

 

(a)     the power or matter relates to a taxpayer in respect of which the Commissioner or the official has or had, in the previous three years, a personal, family, social, business, professional, employment or financial relationship presenting a conflict of interest; or

 

(b)     other circumstances present a conflict of interest,

 

that will reasonably be regarded as giving rise to bias.