means any taxpayer who-
| a) | was not registered with the Commissioner for the purposes of normal tax as at 26 April 1994 and had not on or before that date applied to the Commissioner to be registered for those purposes; |
| b) | was so registered as at 26 April 1994, but in respect of whom the Commissioner was unable to enforce any law imposing normal tax by reason of the fact that such taxpayer's whereabouts for the purposes of normal tax were unknown to the Commissioner on that date; |
| c) | has previously rendered a return of income to the Commissioner in respect of any year of assessment which ended on or before 31 December 1994, and during the relief period discloses to the Commissioner full and true details of any income, deduction or allowance which were required to be included in such return, but which such taxpayer failed so to include and which were unknown to the Commissioner as at 1 November 1996; or |
| d) | is registered with the Commissioner for normal tax purposes and is liable for any interest, penalty or additional tax in terms of the Income Tax Act, 1962, in respect of the late payment or underpayment of any normal tax, other than normal tax which has become payable as a result of the disclosure by such taxpayer of details contemplated in paragraph (c), in relation to any year of assessment which ended on or before 31 December 1994 and who- |
| i) | submits all returns of income for all years of assessment ending on or before 31 December 1996, on or before the last day of the relief period; or |
| ii) | makes arrangements with the Commissioner during the relief period to submit all returns of income in respect of- |
| aa) | all years of assessment which ended on or before 31 December 1995, within three months after the last day of the relief period; and |
| bb) | any year of assessment ending during the 12 months' period ending on 31 December 1996, within 15 months after the end of such year of assessment; |