Who must register as a tax practitioner
Who must register as a tax practitioner in South Africa, the exemptions for employees and supervised staff, the disqualifications, and the process.
By Achekam · · 4 min read · For Accountants & audit firms in South Africa
A bookkeeper who helps her clients fill in their returns. A trainee accountant who prepares returns that a partner reviews. A financial manager who handles his employer's VAT. A retired accountant who completes returns for friends without charging. Which of them must register as a tax practitioner?
The answer matters to each of them personally and to any practice that employs them. South African law draws the line by what the person does and for whom, with a short list of exemptions. This article sets out who must register, who is exempt, what bars registration, how the process runs, and how a practice can keep track of its own people.
The activity that triggers registration
SARS says a natural person must register as a tax practitioner if they give advice to another person on the application of a tax Act, or complete or assist in completing a return for another person.
Both limbs are broad. "Advice" includes telling a client how a tax rule applies to them, not only formal opinions. "Assist in completing" includes preparing figures for someone else to submit. The bookkeeper in the opening paragraph, who helps clients fill in their returns for a fee, is squarely within it.
The exemptions
SARS says individuals are exempt from registering if they give tax advice or complete returns:
- for no consideration;
- for their full-time employer; or
- under the direct supervision of a registered tax practitioner.
These exemptions come from section 240(2) of the Tax Administration Act.
Applied to the opening examples: the retired accountant who charges nothing falls within the first exemption. The financial manager handling his employer's VAT, as a full-time employee, falls within the second. The trainee whose returns a registered partner directly supervises falls within the third, provided the supervision is real. A partner who signs off returns they have never looked at is not directly supervising anyone. If the practice relies on this exemption for its trainees, record who supervises whom and keep evidence of the review on each file.
Each exemption is narrower than it sounds. The retired accountant who accepts a "thank-you" payment, or the financial manager who also helps the managing director with his personal return, may have stepped outside it.
Joining a Recognised Controlling Body
SARS says that to register, a person must belong to or fall under a Recognised Controlling Body, meet that body's minimum qualifications and experience, and have no convictions for the offences listed in section 240(3) of the Tax Administration Act.
The controlling body is the gatekeeper. Its membership requirements, and its rules on continuing education and conduct, apply on top of SARS's own. For SAICA members, those ongoing requirements are covered in CPD hours for SAICA tax practitioners and staying registered as a tax practitioner.
Five-year disqualifications
SARS says a person may not register or remain registered as a tax practitioner if, in the preceding five years, they were removed from a profession for serious misconduct or convicted of a dishonesty offence or a serious tax offence. They may reapply only after five years.
The words "or remain registered" mean the bar applies throughout, not only at the point of application. A practice that discovers such a history in a staff member's background needs to consider what that person may do for clients.
How registration happens
SARS says the Recognised Controlling Body initiates the registration with SARS once the member meets its criteria, after which the person completes registration on eFiling through the RAV01 form.
So the sequence is:
- Join the controlling body and meet its requirements.
- The controlling body initiates the registration with SARS.
- The person completes the registration on eFiling using the RAV01 form.
One avoidable delay is assuming the second step has happened when it has not. Ask the controlling body to confirm it has initiated the registration before trying to complete it on eFiling.
Recording who is registered in the practice
A practice needs to know, at any moment, which of its people are registered, which are working under supervision, and which should not be giving tax advice at all.
In Achekam, a firm administrator invites colleagues by e-mailed link and gives each a role, and can suspend, reactivate or remove them; the subscription's seat limit is checked on each addition. Roles decide what people can do inside Achekam. They do not record whether someone is a registered tax practitioner, which is a separate question.
That record belongs in the practitioner credentials register. Under TEAM > Practitioner Credentials, a partner, manager or administrator records each practitioner's professional body, membership standing with the date it was verified, and practising authority, with evidence. A credential someone recorded about themself is flagged.
For a tax practice, a useful set of entries per person is:
| Field | Example of what to record |
|---|---|
| Professional body | The Recognised Controlling Body they belong to |
| Membership standing | Current, with the date verified and the evidence seen |
| Practising authority | Registered tax practitioner, or working under a named practitioner's supervision |
| Supervisor | For unregistered staff, the registered practitioner who directly supervises them |
Where to confirm the rules
SARS's page on registering as a tax practitioner explains who must register, the requirements and the exemptions. Go through it with each new member of the tax team in their first week, and record their status in the credentials register before they prepare anything for a client.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
