| A. | These Regulations have effect for and in connection with the implementation of obligations which may arise or arise under— |
| (1) | the following agreements or arrangements, in respect of which these Regulations apply separately except where the context otherwise requires: |
| (a) | the Multilateral Competent Authority Agreement on Automatic Exchange of Information pursuant to the Crypto-Asset Reporting Framework signed by the Competent Authority of South Africa on the 26th of November 2024, with the Participating Jurisdictions as updated and published by the OECD from time to time; and |
| (b) | any other multilateral or bilateral agreement or arrangement between South Africa and another jurisdiction, as updated and published by SARS from time to time, which provides for the implementation of the CARF; or |
| (2) | these regulations in respect of or in connection with obtaining, maintaining and provision to SARS of information regarding a Reportable Jurisdiction Person in any jurisdiction not included under subparagraph A(1) for domestic purposes or subsequent exchange of information when such jurisdiction becomes a jurisdiction included under subparagraph A(1). |
| B. | The OECD developed the Standard for Automatic Exchange of Financial Account Information in Tax Matters (2017, as updated in 2023), which encompasses the Common Reporting Standard (the CRS), and the (2023) Crypto-Asset Reporting Framework International Standard for the Exchange of Tax-Related Information (the CARF), to improve international tax compliance and for automatic exchange of information under an agreement or arrangement referred to in paragraph A. |
| C. | These Regulations reflect the changes to the CARF required to enable South Africa to comply with its obligations under an agreement or arrangement referred to in paragraph A in terms of the CARF. |
| D. | South Africa’s selection of jurisdictional choices under the Commentaries on the CARF does not detract from the fact that these Regulations must be interpreted in accordance with the Commentaries. |
E.
| (1) | The term “Commentaries on the CARF” means the Commentaries on the Crypto-Asset Reporting Framework, released by the OECD in the document titled OECD (2023), International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023 update to the Common Reporting Standard, OECD Publishing, Paris, and as supplemented by— |
| (a) | the OECD (2025), CARF Commitment and Delivery - A Step-by-Step Guide, OECD, Paris; and |
| (b) | the CARF-Related Frequently Asked Questions, OECD, Paris; |
as updated from time to time.
| (2) | In the event of any conflict between the Commentaries on the CARF and the supplementary material in subparagraph E(1)(a), or (b), the former shall prevail. |
