A senior SARS official may enter into an instalment payment agreement only if—
| (a) | the taxpayer suffers from a deficiency of assets or liquidity which is reasonably certain to be remedied in the future; |
| (b) | the taxpayer anticipates income or other receipts which can be used to satisfy the tax debt; |
| (c) | prospects of immediate collection activity are poor or uneconomical but are likely to improve in the future; |
| (d) | collection activity would be harsh in the particular case and the deferral or instalment agreement is unlikely to prejudice tax collection; or |
| (e) | the taxpayer provides the security as may be required by the official. |
