South African Revenue Services Annual Report 2005/06

Meeting report

FINANCE PORTFOLIO COMMITTEE
11 October 2006
SOUTH AFRICAN REVENUE SERVICES ANNUAL REPORT 2005/06

Chairperson:

SARS presentation on Annual report
SARS Annual Report 2005/06 (available at www.sars.gov.za).

SUMMARY
The Committee was briefed by SARS on its 2005/06 Annual Report. An amount of R417, 3 billion was collected in the 2005/06 financial year. Changes to macro economic indicators such as final household consumption explained why revenue performance varied even within one fiscal year. The revenue target for this year was set at R456, 8 billion and SARS was currently R17 billion above the target. The Minister of Finance would announce the new target on 25 October 2006 as part of his Medium Term Budget Policy statement. The new target would clearly be more substantial than the initial target. There would be a knock on effect on the R501, 7 billion figure for the next financial year.

The Commissioner noted the increasing abuse and misuse of trusts by high net worth individuals and business people and SARS would be focusing on this area. The construction industry had had a fair share of the economic take in terms of the recent growth. The industry was reflecting all sorts of malpractice. The challenge was how to find the skills and staff to deal with such problems.

The Commissioner said that people who were boasting about being able to evade tax should be informed that their days were numbered. SARS had tools to identify such people and was currently looking at the top five hundred earners. These were the people with the most potential to use trusts. There was a section of the society that believed that it was proper to show off that they were not contributing their fair share. The challenge was for all South Africans to make it clear that such anti-social and destructive behaviour was nothing to be proud of and that such people should be kicked out of golf clubs and other such institutions. This was a social challenge and the country should decide what kind of culture was acceptable. Crime was crime and one could not distinguish between hijackers and those involved in tax invasion.

Members raised a number of questions that included the following:
- What measures had SARS put in place to deal with tax evaders.
- What were the reasons for the low level of success in customs searching luggage.
- What were the reasons for the disappointing response to the amnesty offer.
- Was SARS formulating alternatives to the Regional Services levy.
- What challenges were posed by the quota imposed on Chinese goods as it did not apply to Taiwan, South Korea and Vietnam. How would border posts distinguish between goods from China and the other countries.
- Whether the amnesty period would be extended.
- Should not the number of individual taxpayers be higher than it is was currently?

MINUTES
Mr Pravin Gordhan (SARS Commissioner), Mr L Radebe (Deputy Chief Operating Officer), Mr L Wort (GM: Corporate Communications) Mr K Louw (GM: Legal and Policy), Mr E Keiswetter (Chief Operating Officer) Mr O Magashule, Ms J Padiachy (GM: Office of the Commissioner), Mr J Makwakwa (GM: Enforcement), Ms Mandisa Mokwena (GM: Risk), Mr Prakash Mangrey (GM: Finance), Ms T Mabaso (GM: Services and Channels), Mr T Marx (GM: National Managed Operations), Mr G Ravele (GM: Government Relations), Mr B Hore (GM: Strategy, Modernisation and Technology), Mr I Pillay (GM: Enforcement and Risk) represented SARS. The delegation was accompanied by a number of people from various border posts/ports of entry across the country.

The Commissioner made the presentation (see document attached). He said that an amount of R417, 3 billion was collected in the 2005/06 financial year. He hoped that Treasury had spoken to the Committee about the consequent deficit as a percentage of the Gross Domestic Product (GDP) in its meeting with the Committee the previous day. Changes to macro economic indicators like final household consumption explained why revenue performance varied even within one fiscal year. The Portfolio Committee had passed legislation that would allow the writing-off of debts. Regulations to the legislation were being reformulated on the basis of public comments. The legislation would have a great impact on the total amount of debt because half of the R66 billion revenue debt was not collectable. The real clean debt was R6, 8 billion.

He said that SARS had received unqualified audit reports on administered revenue and own accounts. There were two emphasis of matter in respect of administrative revenue. The revenue target was set at R456, 8 billion and SARS was currently R17 billion above the target. The Minister of Finance would announce the new target on 25 October 2006 as part of his Medium term Budget Policy statement. The new target would clearly be more substantial than the initial target. There would be a knock-on effect on the R501, 7 billion figure for the next financial year.

The Commissioner highlighted several challenges:
- Sustaining and expanding a compliance culture. There were some challenges in the informal business and large business sectors.
- Taxpayer non-compliance. The increasing abuse and misuse of trusts by high net worth individuals and business people. All sorts of transactions went through trusts. This was one area on which SARS should focus. The construction industry had had a fair share of the economic take in terms of the recent growth. The industry was reflecting all sorts of malpractice. The challenge was how to find the skills and staff to deal with such problems.
- Increasing visible audit coverage. The less coverage the greater was the temptation to avoid tax.
- Increasing skills and capacity on the customs side. Political leaders were now talking about integration in the Southern Africa Development Community (SADC) and a movement towards a customs union.

Discussion
Ms J Fubbs (ANC) noted the figure of 4, 8 million individual taxpayers reflected in the presentation. She asked if this figure should not have been higher - given adult population numbers, the reduction in unemployment and rising salaries. The government had managed to tackle slippery individuals and companies. The Commissioner had referred to problems in the construction industry. She wondered if SARS had looked at individuals involved in small companies that earned a lot of money. The problem was that everything they used or lived in was not in their name. There was a number of people who boasted on how they could evade SARS. She asked what measures SARS was putting in place to deal with such individuals.

The Commissioner replied that there were a number of factors that contributed to the figure of 4, 8 million. The Minister of Finance had increased the threshold for payment of taxes over the last five years. It started at R18 000 a while ago and was now at R40 000. People who were below the R40 000 earning range were outside of SARS's radar screen. The challenge was to find out how many people were employed but fell outside the R40 000 range. There could well be a few million people who were in that category. It was hoped that SARS would have a better feel of the figure later this year.

The second factor was the Standard Income Tax on Employees category (people who earned between R40 000 and R60 000). SARS did not have individual records of who these people were but the feeling was that there was about two to three million people in this category. Thirdly, there was an element of non-registration. SARS would fine-tune this factor and determine where these people were found. It was using information from various sources and some of the information was best kept by credit bureaux. It did not get the names of the individuals but income ranges and the number of people who applied for credit in different institutions. SARS was using the information with an adjustment factor because people tended to inflate their income in order to get credit. The figure should probably be a million or two more. People in this category were likely to be low-income earners.

Mr Makwakwa replied that those who were boasting about being able to evade tax should be informed that their days were numbered. SARS had tools to identify such people and was currently looking at the top five hundred earners. These were the people with the most potential to use trusts. It also conducted integrated audits that involved looking at companies together with their directors and related parties. SARS used information from third parties to link people to different entities. It also interacted with the Master’s Office. Trusts were not linked to SARS's system. Linking the Master's Office to SARS's systems would have enabled the later to automatically update its information whenever a new trusts was registered. SARS was working on a process of integrating the systems so that it could pick up new trusts immediately. It was also looking at media as a way of getting information on individuals who were not paying their fair share.

Ms Mokwena replied that there was a mechanism through which people reported individuals whom they thought were outside the tax net. This enabled SARS to do risk profiling on the people. There were tools that were used to interact with third party data like the Companies and Intellectual Property Registration Office. There was also co-operation with other law enforcement agencies. SARS's used research trends and external environmental scans to identify people who fell outside the net and to determine the sector contribution to the GDP versus what the sectors were declaring.

The Commissioner added that SARS was developing capacity to match information from different sources and to analyse better. There was a section of the society that believed that it was proper to show off that they were not contributing their fair share. The challenge was for all South Africans to make it clear that such anti-social and destructive behaviour was nothing to be proud of and that such people should be kicked out of golf clubs and other such institutions. This was a social challenge and the country should decide what kind of culture was acceptable. Crime was crime and one could not distinguish between hijackers and those involved in tax evasion. He invited the Committee to join SARS in making it more uncomfortable for people to flagrantly boast about tax evasion.

Mr I Davidson (DA) noted that he had sent inquiries to SARS. He congratulated SARS for the effectiveness and efficiency with which the inquiries were dealt with. He focussed on the question of small business tax amnesty. A total number of 950 applications were received out of the informal sector. There had been comments in the press that the reaction to the amnesty had been somewhat disappointing. The question was what were the obstacles. The Committee had fully supported the amnesty process when it was proposed and had expected a far higher take-up. It was still early days and there might be a surge towards the end.

He continued that there were target success rates in relation to anti-smuggling activities. He asked if the rates were based on international norms. What were the reasons for the low levels of success particularly in relation to people and bag searches. On the issue of people capacity processing, he asked if each staff member had handled applications in the region of 3 620. What was the international norm for this?

Mr Keiswetter replied that the number referred to the actual number of people who worked in the relevant area. This included people from the mailroom through to the point were returns were accessed. In 2003/04 SARS had processed about 10 million returns using 3 780 staff as opposed to 12 million by 3 620 staff members in the current year. This meant that the processing volume had increased by 20% whilst SARS was at a 95% level of staffing. It was difficult to benchmark processing capacity. Benchmarking depended on the degree of automation that other countries had and the assessment approach that they had adopted.

The Commissioner replied that there was a number of factors at play with the tax amnesty. There was a specific amnesty granted by the Financial Intelligence Centre (FIC) to practitioners during the foreign exchange and tax amnesty. Practitioners were not required to report things that they had become aware of. It had taken some time for the FIC to process such an exemption this time around. The exemption had not had not yet been gazetted and was work in progress and nearing completion. The Minister had given the necessary approval. The absence of the amnesty had inhibited practitioners from becoming directly involved in the process as was the case in the earlier process.

He said that there was also an element of scepticism. This was a different kind of market characterised by less tax awareness, less familiarity with obligations and perceptions that still had to be removed. The number of application received at this point appeared to be greater compared to the other amnesty process. The process was slow. He hoped that the Committee was familiar with human nature of "waiting to see what would happen". SARS could put more resources into making people aware of the benefits. There were serious negative consequences for people who would not use this opportunity. The extension of the deadline was the prerogative of the Minister.

The Commissioner conceded that SARS could do better in relation to the anti-smuggling activities. The key in customs was risk-related information. The better the capacity to detect trends, the better would be the success rate. It was still early days for South Africa. Some countries had taken 20 to 30 years to develop proper systems and had continued to enhance them. SARS was on the right track.

Mr Radebe replied that it was important to highlight that the World Customs Organization (WCO) anti-smuggling framework of standards governed SARS anti-smuggling activities.

Mr A Moloto (ANC) was concerned that government departments were also guilty of non-compliance. The Commissioner had indicated that SARS would sign a memorandum of understanding (MOU) with government departments. He asked if the MOU would help to address the challenge in relation to government departments. He also asked how confident SARS was that would be able to deal with debt book in the long run.

The Commissioner replied that the issue was largely of capacity and skills rather than intent. SARS was interacting with and advising departments on how to change their practices. The entities were also appointing tax managers who understood the rules and could liaise with SARS in order to better understand their obligations.

Mr Pillay replied that the debt book had been increasing year on year for the last ten years prior to last year. It was brought under control over the last two years. Last year it came down by R2, 7 billion for the first time. SARS was beginning to get on top of it and it should be able to do better with the new regulations. There were a few tools such as debt management automated solutions that were still required. He was confident that SARS would get there.

The Commissioner added that a recent conference of tax administrators and commissioners had indicated that debt in tax administration was a world-wide problem largely due to the appearance and disappearance of business. SARS compared fairly favourably and would have put systems in place to improve the situation if it had the money to do so.

Dr M van Dyk (DA) said that the Commissioner had mentioned 3, 2 million call centre queries and 4,2 million visitors to SARS's branch offices as some of the operational highlights. He asked if the calls and visitors were in connection with the completion of tax. One could say that there were problems if the calls and visits dealt with how to complete the forms. The presentation indicated that 181 criminal cases were finalised. He assumed that some of them were dealt with on legal basis and asked what were the costs and benefits for dealing with them. He asked if the Commissioner thought that the amnesty period would be extended. The Regional Services Council levies had been phased out and he asked if SARS was formulating alternatives to the levy.

Ms Mabaso replied that most of the visitors had queries on how far their assessment had progressed, how to register and what were the tax obligations. A lot of people visited the offices during the filing seasons. The Commissioner added that there was a mixture of reasons for this. Indications from surveys were that South Africans wanted more opportunity to actively interact. The challenge was to double the number of access points to ensure greater interaction.

Mr Louw replied that no replacement tax was announced when the phasing out was announced. The cost to government was R7 billion for the current year and R24 billion over the MTEF period. The indication at this stage was that there would be no replacement in the short term. SARS could not make a commitment that there would be no replacement tax as this was a policy call and the prerogative of the Minister and government. A lot would depend on the revenue needs of municipalities and their rights to levy tax.

The Commissioner said that experience worldwide had shown that unless an administration could demonstrate a workable and effective enforcement arm, nobody took compliance seriously. It was important to investigate and prosecute criminal acts. SARS did not prosecute offenders but handed over to its investigation results to the National Prosecution Authority (NPA). The challenge was to have the customs and tax technical skills developed in the NPA. There were complex cases where the NPA would bring people from outside to act as prosecutors to ensure that the right skills were available. This increased the costs because one had to pay private sector costs. More recently, SARS's legal fees were around R R30 million per year. This was a required legitimate expense. It was important to avoid a situation where people who had all the money could buy the best legal skills and keep agencies like SARS on the hop. There were cases like those in the public domain. All sorts of accusations had been made against SARS or the Commissioner. The bottom line was that loads of money afforded well-resourced individuals to defy and defer justice. This was a social challenge about how the court should deal with the matter and what precedent should be set. This challenge was not unique to SA. The US Senate had looked at such issues and named people engaged in certain activities.

Dr van Dyk said that it was important to respond to the question in the context of the gains from the cases.

The Commissioner replied that it might be important for Dr van Dyk and himself have a private conversation to help Dr van Dyk understand that compliance was the crucial foundation for ongoing and sustainable revenue collection. It was the compliance culture and behaviour that determined whether one could sustain the revenue performance. South Africa would be making a big mistake that it would regret ten years down the line should it allow the compliance culture to drop or allow high profile or highly connected people to break the law.

Mr B Mnguni (ANC) referred to people who had just started working and asked how they were complying with their tax obligations. He asked if employers could be held accountable if newly employed people did not comply with their obligations. There was a decrease of operational costs in 2000/01 and an exponential increase thereafter. He asked what were the reasons for the increase.

The Commissioner replied that it was difficult to specify what new people into the market were doing. A lot depended on the employer. For instance, not all estate agents did what they were required to do: deduct pay as you earn (PAYE) from people to whom they paid commissions for the sale of properties. The Estate Agency Board would say that agents were doing all the right things but the FIC had recently highlighted and pinpointed the estate agency profession as one area in which money laundering was taking place. It was well know that large sums of money exchanged hands in the context of property transactions. PAYE was a problem and sometimes private expenditure was being claimed as business expenditure. False transactions and all sorts of manipulation took place in order to minimise formal income declared on the one hand and transfer duty on the other. PAYE was also an issue in the construction industry. There were labour brokers and independent constructors involved in order to minimise the burden of the employer. It was the employer’s obligation to deduct PAYE and act as an agent of the State. There was a need for more auditors skilled in PAYE.

With regard to the cost of collection, he said that SARS was still sitting at about 1% overall and any increase was a minor increase. It all depended on the revenue collected in a particular year. SARS would seriously ask people to talk about a fixed percentage for the next two to three years. This would give certainty and allow proper planning. In strict commercial terms, SARS was a very well run business because their costs were very low and the returns very high. The challenge was how to invest more so that it became more productive.

Mr S Dithebe (ANC) asked what was the relationship between the 181 criminal cases that had been finalised and the 105 anti-corruption cases. Did the 105 figure refer to taxpayers or members of the organisation?

The Commissioner replied that the number should be 1 181 criminal cases. The 105 figure referred investigations of the staff.

Mr S Asiya (ANC) said that there was an allegation made during the last financial year that 60 000 cheques were issued to people who did not deserve them. He asked, if the allegations were true and what remedies were put in place to ensure that this did not happen again. He added that it was important to ensure that the borders were secure.

The Commissioner said that it was not true that SARS had issued 60 000 cheques to people who did not deserve them. He agreed that it was important to tighten up the border posts. Customs had consisted of about 800 officers five or six years ago. Customs was a decimated area of government infrastructure. SARS was building up the number and it was important to beef up the enforcement capacity. There were enough parallels across the world and assistance offered in order to model SARS with other tax administrations. China was doing fantastically well and probably better than any other country in terms of training customs officers. China probably had between six and ten thousand people in training in their customs training college at any one time. They had about a 75 000 strong customs services.

Mr I Harding (ID) asked in which categories was SARS experiencing staff shortages and if it recruited staff directly from tertiary institutions. There was a widely held belief that SA had a fairly complicated tax system that impacted on compliance in the small business sector. The Commissioner had indicated that there was a level of scepticism in the small business sector. The question was the extent to which this belief contributed in small businesses not taking up the amnesty.

Mr Magashula replied that the number of vacancies did not necessarily reflect areas of need from a skills point of view. The number reflected the high turnover areas in the business. For instance, there were high turnovers in call centres, assessing and auditing. The top four auditing companies usually snatched up all new entrants into the auditing field very early. SARS was finalising an agreement with Thuthuka, a bursary scheme run the South African Institute of Chartered Accountants. Organisations subscribed to the scheme and sponsored students from the very first year. SARS had submitted a request to have at least ten of the students. Processes would be designed to ensure that the students were retained in the organisations once given employment. SARS had been very successful in retaining people under its internship programme.

Mr Louw agreed that there were areas of the tax law or system that were complex. One could not just have a simple approach in relation to formal and big businesses. The tax challenges should follow the challenges and development that were taking place in the economy and the market. There were also new challenges and new instruments coming into the market. This was a worldwide phenomenon. It was not just the level of complexity within the specific tax but also the multiplicity of different taxes that complicated issues for small business. SARS was trying to cut down on the number of taxes. The abolition of RSC levies was one good example. There were also thresholds that determined if a business was expected to pay a certain tax. He used the Skills Development Levy as an example. Businesses that had a payroll that was less than R500 000 were not required to pay the levy. There was also a threshold in relation to Value Added Tax. SARS had also cut down on the number of forms that small businesses had to fill.

Ms Fubbs referred to the small business tax amnesty. The anomaly that should be explained was the 6 101 enquiries at branch offices and 7 273 calls received by the Small Business Amnesty Call Centre. Assuming that a person had called twice and that 1000 applications were received, the question would still be why there was such a small number of applications compared to enquiries. Was SARS saying that some of the people who had made enquiries were told that they did not fall into the relevant category? She was not aware that SARS took part in patrols. She asked if the patrols were done in conjunction with the South African Police Service. Patrols seemed to be the most successful anti-smuggling measure.

Mr Wort replied to questions by Ms Fubbs and Mr Harding on the tax amnesty. He said that members should not read much into the numbers of enquiries and the applications. SARS could not, at the time of the enquiry, tell if a person would get an amnesty. There were requirements like full disclosure that had to be satisfied before amnesty could be granted. The qualification criteria were very clear. People might also make enquiries and decide to make application at a later stage. It was expected that the number of applications would increase. The issue of confidence was central to the take-up of the amnesty process. The second economy was largely unregulated and access to such business was difficult. SARS had resorted to the mobilisation approach of communication rather than formal advertisements in newspapers. Another challenge was record keeping in the sector. Businesses should be able to sustain record keeping once they had regularised their affairs.

The Commissioner added that SA had done the relatively easy work. The amnesty would begin to knock into the next circle of South Africans who needed to get into the tax net. This was an experience shared by all developing countries and SA was doing much better than most countries. This process came with its own specific challenges. It was not about people who were fully tax literate, knew everything and would immediately respond upon contact. Unconventional ways would be required to identify and contact the people. There was a need to continually simplify tax law and its administrative requirements. SARS was currently working on this difficult task. It was important to have some discussions on this segment of the society and identify the kinds of challenges that it presented. It was not simply that they did not want to be registered or to be part of the system. The challenge was how to create conditions that would enable them to become part of the system.

A Member said that people who evaded tax were well known. He asked why it was so difficult to deal with them. He was concerned that most of the time the revenue estimates were way off the mark.

Mr Gordhan replied that the patrols were carried out by about two to three hundred anti-smuggling officers at different ports of entry. They drove along the border lines and intercepted suspicious goods. There was a need to increase the number and capacity of the team. It was not easy to estimate how much revenue would be collected in any given year. There was certainly no intention to under estimate the revenue to be collected.

Mr Davidson said that the Minister of Trade and Industry had recently imposed a quota in respect of goods from China. He asked what types of challenges this posed on SARS bearing in mind that the quota did not apply to countries like Taiwan, South Korea and Vietnam. How would the border posts be able to distinguish between goods from China and the other countries? He noticed that targets were being met roughly within about 90 to 100 days. He asked if SARS had a timetable in respect of when the turn-around time would come down to 40 days.

The Commissioner replied that it was simple to identify goods from China from other goods. One could simply look at the documents that accompanied the goods. However, there was the issue of trans-shipment and it was possible for goods to be manufactured in country A and be sent to country B which would then put a label saying that the goods were made in country B. This had been happening in Southern Africa in some of the countries that had preferential trade deals with South Africa. A T-shirt would come fully made into country X and country X would simply attach a label saying "made in Country X". The goods would then be exported or imported into SA at preferential rates. This was one of the games that importers played and the retail industry should play a different, more assertive and quality control role.

He said that the agreement between China and SA would indeed present some challenges. One would have to ensure that all goods from China were properly recorded in all ports of entry and properly checked against the quota. The way the agreement was crafted meant that SA had taken the responsibility of controlling the quota. There was no duty on China to ensure that goods that had left China destined to SA did not exceed the quota. SARS was in discussion with the Department of Trade and Industry to ensure that the policy design and the administrative requirements were consistent with each other. The Chinese Minister of Customs had recently visited SA and the governments of the two countries had entered into a mutual administrative assistance agreement. The agreements was a crucial legal piece in customs terms that would ensure that SA would get co-operation from China as it (SA) investigated fraudulent activities. The assistance could come in the form of documents, information and valuation data that would ensure that investigations were carried out on proper basis. The information could even be used in court. Many countries were willing to give information to SA but the problem was that such information could not be used in court.

Mr Gordhan said that there was also the problem of round tripping of goods. Instead of coming directly into the country, goods would be sent to one country and then end up in SA. Officers should be alert, know what the quotas were and be to stop and inspect the right consignment.

Mr Mnguni said that the cash flow statements indicated that there was some interest payable to some borrowings connected to the centre in Gauteng. He asked what was the policy in relation to purchasing building. SARS was paying rent of about R1, 7 million in relation to a lease of a building. He wondered if it was not cheaper for SARS to get a contractor who would build them their own property. SARS could not reach the target in relation to VAT due tax rebates given to small businesses and individuals. He appreciated the rebates but wondered if this would not shrink the tax base. There was a tendency for SARS to sit down and negotiate with rich persons who owed tax. It did not negotiate with poor people but simply used the full might of the law. He asked if this was SARS's policy to discriminate against poor people.

Mr Makwakwa replied that SARS had no policy that discriminated between rich and poor people. SARS engage people so that it could better understand their situations.

Mr Moloto said that customs administrations world wide had the capacity to intercept goods in the sea and in the air. He asked if SARS was looking at the possibility of acquiring boats and choppers in order to strengthen customs administrations. The Commissioner had indicated that SARS could not do certain things due to the lack of funds. There were huge sums of money that were being surrendered to the National Revenue Fund. Government institutions, including Parliament, had experienced massive under spending in the past. One wondered why such money was not given to the money-making machine called SARS to get the capacity it required to collect more tax.

Mr Radebe replied that he would love to have the boats and choppers to do the job effectively. The issues were whether SARS could afford them and whether it had people who could operate them. Customs was a very crucial area to look at especially for 2010 purposes.

The Chairperson agreed that it did not make sense that SARS could be constrained by lack of funds. This was perhaps an issue that should be discussed with National Treasury.

Dr van Dyk wondered if the Commissioner's suggestion that the two should have a private discussion on the purpose of enforcement was meant to embarrass him. He was not comfortable with the suggestion. Members of the Committee were here to ask questions and should be given answers and not negative comments. There were 1 181 criminal cases from 14, 8 million processed returns. This meant that money was spent on 0, 007% of the returns. One could conclude that the money was not well spent. The Commissioner had acknowledged that there were not enough staff and branches. It might take a number of years to get more branches. This was a very important issue that should be very high on the priority list of SARS. This could be one of the reasons of the poor performance in the tax amnesty applications at this stage. More branches could lead to more people coming into the tax net.

The Commissioner said that there was no intention to embarrass any member. The intention was to invite the member to a private discussion so that the two parties could share some information. He did not agree that the money spent on the criminal cases was wasted. It was important to discourage or disincentivise people from evading tax.

Mr Dithebe said that there was a slight change in the revenue collected as a percentage of the GDP from the 2004/05 financial year. He wondered if the conservativeness in relation to the forecast revenue was due to lack of confidence in the part of SARS to deal with debts under dispute.

The meeting was adjourned.