A senior SARS official may not "compromise" any amount of a tax debt under section 200 if—
| (a) | the "debtor" was a party to an agreement with SARS to "compromise" an amount of tax debt within the period of three years immediately before the request for the "compromise"; |
| (b) | the tax affairs of the "debtor" (other than the outstanding tax debt) are not up to date; |
| (c) | another creditor has communicated its intention to initiate or has initiated liquidation or sequestration proceedings; |
| (d) | the "compromise" will prejudice other creditors (unless the affected creditors consent to the "compromise") or if other creditors will be placed in a position of advantage relative to SARS; |
| (e) | it may adversely affect broader taxpayer compliance; or |
| (f) | the "debtor" is a company or a trust and SARS has not first explored action against or recovery from the personal "assets" of the persons who may be liable for the debt under Part D of Chapter 11. |
