SARS Binding Class Ruling

Date: 5 September 2025

Official SARS Section 12B ruling enabling tax-efficient renewable energy investments

BCR 88 is currently the most definitive SARS guidance on how section 12B applies specifically to class members of partnerships investing in renewable energy assets. It offers clarity on the interpretation of “generation assets” and the procedural mechanics for deducting allowances, importantly extending the scope to include integrated battery systems and supporting infrastructure.

Our business model is fully aligned in accordance with the SARS ruling

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