In December 2021 and January 2022, SARS made adjustments to the act to facilitate the control of Advanced pre-payments on import shipments. This is relevant to any importer who must pay a deposit or part payment prior to shipment and requires that an APN number is secured and used as reference on all prepayments. Whilst the system to apply for an APN have been in place throughout 2022 on your e-filing platform, banks have not rolled out this requirement pending a directive from the Reserve Bank making the submission of APN numbers mandatory. As such it has been largely ignored until now. We have established through our banks that this will become mandated in quarter 2 of 2023 and so we raise this important process to your attention for implementation within your finance structures.
Attached, and through links below, are clear explanations to this process and we encourage reading the same in detail.
https://www.sars.gov.za/sc-cc-33-submission-of-advance-import-payments-external-guide/
https://www.sars.gov.za/apn-presentation-29-nov-21/
In brief we note the following:
Any payment or part payment made to a supplier prior to inbound clearance must be done with an authorised APN reflected.
APN numbers for each payment are applied for via your e-filing platform and expire if not used within 30 days.
Any subsequent payment on the same shipment (balance of payment) also require addition to the APN registration but are made against the initial APN number secured for the first payment and are logged under that APN number in e-filing as subsequent payments (i.e.: the initial APN becomes the master to all subsequent payments on the same shipment)
When SCT handles your customs clearance, we now need to insert this APN into the B/E to allow the reconciliation of payments with proof of entry into South Africa. Please note that we have no way of knowing whether an APN number (hence pre-paid) was required and therefore it is the responsibility of the importer to advise SCT of the same with their clearing instruction. If you fail to advise SCT, resulting in processing a VOC to correct this, we will, unfortunately, have to raise a VOC fee of R250 as we pay for each submission made to SARS.
As the APN number is complex, and the accuracy of capture when framing the BE critical, we ask that an electronic version of the APN confirmation from e-filing is sent with your clearing instruction to SCT so we can copy and paste the number ensuring 100% accuracy.
Because the Reserve Bank will mandate this requirement for quarter 2 in 2023, we strongly recommend it is implemented with immediate effect into your processes so that any concerns and processes can be adjusted prior to implementation. We believe a penalty system will apply to non-conformance.
Once you have read and digested the attached, please feel free to contact Nick Browne if you have any questions and Nick and our team will do the best to either answer or research the answers as required.
Thank you in advance
Gary Knight
Managing Director