BIBLE
SOCIETY OF
29 October 2007
The
Chairperson
Standing
Committee on Private Member's Legislative Proposals and Special Petitions
8000
Dear
Ms Mentoor
I
refer to our telephone conversation of Friday 26 October 2007.
The
Bible Society of South Africa (BSSA) earnestly desires to work fully with the
Standing Committee to reach a responsible decision regarding Act 15 of 1970, Bible
Society of South Africa Act.
Due
to very short notice, please accept that the input of this letter is
preliminary and a first draft only. Owing to an exceptionally heavy work
programme, which I shared with you and Mr P-J Gerber, it will be absolutely
impossible for me to give the necessary attention to this matter before the
second half of November. The Global Board of the United Bible Societies (UBS)
meets in
The
BSSA is prepared to meet the Standing Committee on Friday 23 November to share
with you a presentation on our work as well as our request to remain
incorporated under Act 15/1970.
The BSSA kindly requests that the Standing Committee
separate the different churchs' Acts from Act 15/1970, Bible Society of South
Africa Act. The BSSA is NOT a church and Act 15/1970 should be handled separately.
Thank
you for the opportunity to share with you some preliminary and provisional
remarks in favour of incorporation under the Act.
1
On a daily basis ALL work and activities of the BSSA are
regulated through Act 15/1970. Act
15/1970 regulates:
a.
The controlling bodies of the BSSA namely the National and
Regional Boards, as well as the Executive Committee;
b.
Our mission and task of Bible translation in all the
languages of our country, as well as publication and Bible programmes;
c.
Our promotion and fundraising programmes;
d.
Our marketing and distribution programmes;
e.
Our contracts with clients such as banks etc.;
f.
Our human resources eg. service contracts, pension and
provident-funds;
g.
All funds, amounting to an annual turnover of R70 million,
auditing.
h.
etc.
2
Act 15/1970 makes it possible for the BSSA to enjoy tax
exemption. It is crucially important
for the functioning of the BSSA, as we are a non-profit organisation with a
mission to make affordable Bibles available to all people and in all the
languages of our land. The BSSA falls,
at present, under Art 10.1.(cA) of the Income Tax
Act. Tax exemption on an
other basis could be most cumbersome.
The BSSA cannot obtain tax exemption on the same basis as churches. –
SAICA Legislation Handbook p 544, 5a-c.
3
It is an established right/interest of the BSSA which cannot/may not be taken away without sound valid reasons.
4
Die BSSA's unique identity is entrenched in Act 15.
5
The BSSA is not a church! Act 15/1970 states that it is an
"educational and religious organization".
6
The BSSA is a business industry – trading in Bibles, without
a profit objective. We serve all
Christian churches and the Christian community of
7
Nothing in the Act is discriminatory or unconstitutional. The BSSA would have no problem should other
faiths, with the mission of distributing their holy Book, also be incorporated
by an Act.
8
Should incorporation by the Act be repealed, registration on
any other basis would of necessity involve the Bible Society in substantial
costs. Transfer costs for a new
entity would also have to be met.
9
Much confusion could result should the BSSA change
its current incorporation, for example, testaments and legacies to the BSSA
(20% of the BSSA's income), and this could give rise to possible losses for the
Bible Society.
10 Other options are not
immediately obvious, given the unique character and business of the BSSA.
11 The BSSA has been active since
1820 as a Christian service organisation in South Africa and deserves the
privilege of legal incorporation because of its unique contribution to
literacy, the orthographical development of the languages of our country, the
promotion of a Biblical value system, the translating of the Bible in all 11
official languages, the distribution of affordable Bibles (free to prisoners).
Should
the BSSA have to be regulated in any other way – which we hope will not be the
case – it will take at least 12 months for the BSSA to have enough time
to investigate other possibilities, and the implementing thereof.
The
BSSA renders an essential service to all Christians, language groups and
churches in
A
sincere, yet earnest request, is hereby made that the
possible repeal of the Act be withdrawn, and that discussions rather be held later
regarding possible amendments – for the sake of allowing the BSSA to continue
unhindered with its crucially important task for/in
I
hope that these few thoughts are of some help.
Please let me know if I can be of further assistance. We really want to co-operate fully with you
for a satisfactory solution for all parties.
Yours
sincerely
Gerrit
S Kritzinger
Chief
Executive Officer