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For South African businesses engaged in international trade, the administrative burden of managing foreign exchange payments is a constant factor in operational planning. Since late 2023, the Advance Payment Notification (APN) system has been a mandatory step for importers making upfront payments to foreign suppliers. While intended to increase transparency and combat illicit financial flows, the process has often introduced delays and increased paperwork for small and medium-sized enterprises (SMEs).
A significant shift is on the horizon. SARS recently published a draft amendment to the rules under Section 120 of the Customs and Excise Act, 1964. The core of this proposal is a plan to double the current threshold for APN submissions, moving the requirement from R50,000 to R100,000. This change represents a pragmatic move by the revenue service to reduce friction for smaller transactions while maintaining oversight on larger capital outflows.
Why This Matters to South African Businesses
The proposed amendment is particularly relevant for SMEs and growing businesses that frequently source inventory or specialized equipment from international markets. Currently, any advance payment exceeding R50,000 triggers a mandatory notification process via SARS eFiling. This involves capturing specific data and obtaining an APN reference number before an authorized dealer (your bank) can finalize the payment.
By raising this limit to R100,000, SARS is effectively removing a significant number of routine transactions from the regulatory net. For a business owner, this means faster turnaround times for overseas orders, reduced administrative costs, and a more agile supply chain. In an environment where the Rand’s volatility can impact pricing daily, the ability to settle smaller invoices quickly without a “waiting game” at SARS is a welcome relief.
Key Business Implications
The draft amendment introduces several practical changes that directors and financial managers should note:
- Increased Threshold: The primary change is the shift from R50,000 to R100,000 for APN requirements. Payments below this new limit will no longer require a formal notification to SARS prior to settlement.
- Currency Fluctuation Protection: One of the most practical additions is the “fluctuation carve-out.” If a payment is initiated when the value is below R100,000, but the Rand weakens before the bank settles the transaction—pushing the value above the threshold—an APN will still not be required. This eliminates the risk of technical non-compliance due to market volatility.
