168. Criteria for instalment payment agreement
A senior SARS official may enter into an instalment payment agreement only if-
(a) the taxpayer suffers from a deficiency of assets or liquidity which is reasonably certain to be remedied in the future;
(b) the taxpayer anticipates income or other receipts which can be used to satisfy the tax debt;
(c) prospects of immediate collection activity are poor or uneconomical but are likely to improve in the future;
(d) collection activity would be harsh in the particular case and the deferral or instalment agreement is unlikely to prejudice tax collection; or
(e) the taxpayer provides the security as may be required by the official.