CATEGORIES
- (1) Negotiating Tax Debt and Payment Arrangements with SARS
- (37)Accounting
- (2)Accounting for Income Tax
- (1)Accounting for Income Tax
- (9)Administration of Estates
- (1)Advisory Services
- (1)Application of tax rates, s6(2) rebates
- (1)Assessed losses
- (4)Audit, Reviews & Other Services
- (9)Blogs
- (8)Capital Gains Tax
- (1)Capital Gains Tax - Individuals Tax
- (1)Capital Gains Tax Implications of Trusts
- (2)Case study: Home office expense
- (1)Case study: Travel allowances
- (1)Company Formations
- (1)Compliance
- (128)Corporate Tax
- (10)Customs and Excise
- (2)Deceased Estate
- (1)Deductions Pre-trade and prepaid expenses
- (1)Deregistration
- (2)Digital Tool
- (2)Employer and Employee (PAYE and UIF Specific)
- (1)Estate Duty
- (1)Events / Webinars
- (10)Faculty News
- (2)Farming
- (159)Individuals Tax
- (1)Input - Customs Duty
- (3)Interest
- (15)International Tax
- (17)Legislation
- (1)Low interest rate loans and loan subsidies
- (1)Nature of the rights of beneficiaries
- (1)Notional input tax
- (9)Payroll
- (2)Practical Payroll
- (2)Provisional tax (Link with other Taxes)
- (3)SARS Dispute Resolution
- (4)SARS Issues
- (1)Salaried Employees
- (139)Tax Administration
- (2)Tax Administration Part 2B: Resolving Problems with SARS using the Tax Ombud
- (1)Tax Administration Part 3B Dispute Resolution - Objection and appeal
- (3)Tax Update
- (1)Tax implications of loans to trusts
- (1)Tax residence
- (1)Tax returns and payments
- (2)Transfer-Pricing
- (1)Trust Income / Gain Allocations
- (1)Trust types and income allocations
- (8)Trusts
- (76)VAT
- (3)VAT periods
- (1)Wear and tear allowances
- (1)Wills, Estates & Trusts
- (1)Zero Rated
- (1)eFiling
- Show All
VAT Registration for Visa Application Agent
- 02 April 2025
- VAT
- The Tax Faculty Tax Specialist
This article is based on tax law for the year ending 29 February 2026.
Question
A client acts as an agent assisting individuals with visa applications. She receives consulate fees from clients and pays these fees to the consulate. Her fees, combined with the consulate fees she receives, exceed the VAT registration threshold. The question is whether she is required to register for VAT, considering she acts as an agent for VAT-neutral consulate fees.
Answer:
The Problem / Facts
An agent assists individuals with visa applications. The agent receives consulate fees from applicants and pays these fees to the consulate. When combined with their own service fees, the total receipts exceed the VAT registration threshold. The question is whether VAT registration is required, given that consulate fees are VAT-neutral and the agent acts on behalf of clients.
Analysis of the Tax Issues Identified
The key tax issue is whether the agent’s activities amount to a taxable supply for VAT purposes, considering their handling of VAT-neutral consulate fees. The agent’s service fees are clearly taxable. When combined with the consulate fees, the total receipts exceed the VAT threshold.
The critical point is whether handling consulate fees, as part of an agency service, changes the VAT treatment. It is likely that this is considered a separate taxable supply. As such, the agency service would be subject to VAT. Therefore, if the full amount (service plus consulate fees) is treated as income, VAT registration would likely be required.
Relevant Legislation
-
VAT Act 89 of 1991 – Section 54: Governs VAT treatment of agents and the handling of disbursements.
Application of the Law to the Facts
Where an agent is acting purely in an agency capacity, and consulate fees are clearly documented and invoiced as disbursements (pass-through amounts), those fees are VAT-neutral and excluded from taxable turnover.
Accordingly, only the agent’s own service fees should be counted when assessing the VAT registration threshold.
Under these conditions, VAT registration would not be required solely due to the combined receipts, provided the consulate fees are correctly treated and SARS documentation and compliance requirements are strictly followed.