I am deeply endebted to Theo Burrows of the Tax Faculty Team for finally settling this issue.

He has confirmed the tentative view that I expressed in this article. That is, that if the business of letting Air BnB accommodation does more than R1m turnover, then it must register as a vendor and charge VAT.

The bottom line is that AirBnB is commercial accommodation (subject to VAT) and is not the letting of a dwelling (not subject to VAT).

His references from the VAT Act are:

s1 Definition of Commercial accommodation

s12(c) Commercial accommodation is subject to VAT. Residential dwelling accommodation is exempt from VAT.

s23(1) Obligation to register as a vendor

SARS Interpretation Note 42