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Foreign tax credits and rebates – taxpayer treat or trap?

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In an exciting recent development, National Treasury published a set of draft Tax and Revenue Law Amendment Bills, together with accompanying Explanatory Memorandums thereto, for public comment. These draft bills contained a host of robust proposed changes to tighten certain loopholes and inconsistencies in South Africa’s tax laws.

The glitch in our new residency-based system

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South Africa’s exchange control regime has relaxed considerably over the last few years, but the most recent amendments have created widespread confusion around the definition of non-residency for exchange control purposes. In particular: When is a person non-resident for exchange control in South Africa? How do they cease to be resident for exchange control purposes? And what does all this mean?

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