Primary briefing · Gazette
high impact 55245 · R. 7847 · 2026-08-25
GN R. 7847 — VAT Export Delivery Requirements Expanded to Include Licensed Terminal Operators
The Minister of Finance has amended Regulation 8(2)(e)(ii) of the VAT export regulations (originally GN R.316 of 2 May 2014) to update the list of entities to whom goods must be delivered to satisfy the 'exported' definition under section 1(1) of the VAT Act. The substituted provision now expressly includes any terminal operator operating under a licence issued by the port authority in terms of sections 57 and 65 of the National Ports Act, No. 12 of 2005, alongside the existing categories of port authority, master of the ship, container operator, pilot of an aircraft, or the control area of the airport authority. This broadens the recognised delivery points for VAT zero-rating purposes, closing a gap where delivery to a licensed terminal operator — rather than the port authority itself — may not have clearly satisfied the regulatory requirement.
Who is affected
VAT-registered vendors exporting goodsPort authorities and licensed terminal operatorsContainer operators and freight forwardersCustoms and trade compliance advisorsLogistics and shipping companiesAviation and air freight operators What this means for practitioners
Review and update internal VAT compliance procedures to recognise delivery to licensed terminal operators as satisfying the export delivery requirement under regulation 8(2)(e)(ii).
Confirm that documentary evidence of delivery (bills of lading, delivery notes) correctly identifies the receiving entity as a licensed terminal operator where applicable.
Advise exporter clients that failure to align delivery documentation with the amended regulation could jeopardise VAT zero-rating on exports.
Locate the principal regulations (GN R.316 of 2 May 2014) and read the amendment in context to assess any knock-on effects on existing export workflows.