SARB Christmas Gift for Non-Residents: Partial Waiver of AIT Tax Clearance Certificates
- Michael Kransdorff
- Dec 16, 2025
- 2 min read
South Africa’s Reserve Bank (SARB), in response to pushback from the tax and investment community, has partially eased the stringent exchange control rules introduced in October 2025, providing relief for non-resident investors and emigrants with South African income.
Under the updated framework:
Non-resident entities no longer need to apply for an International Transfer (AIT) tax compliance PIN for income transfers.
Dividends from listed companies and interest from regulated financial institutions can now be remitted abroad without requiring tax clearance for non-resident individuals as well.
Remaining AIT Tax Clearance Challenges for Non-Residents
Despite this partial relief, significant compliance issues remain:
Rental income – AIT tax clearance pin is still required from the non-resident beneficiary.
Directors’ and members’ fees – Require either a manual letter of compliance or an AIT tax cleance pin
Certain income streams, including dividends from unlisted companies, interest from unregulated entities, and trust distributions, require Tax Compliance Status (TCS) certificates of good standing from the South African payer.
The ongoing discrimination against rental income and directors’ fees is arbitrary, economically harmful, and administratively indefensible“Why should rental income face weeks of delay while other income can be transferred immediately? There is no rational policy basis.
Non-residents discrimated against with No SDA
The absence of an annual exchange control allowance for non-residents is the major flaw in South Africa's exchange control framework. South African residents enjoy a R1 million single discretionary allowance (SDA) for offshore remittances without tax clearance, but non-residents have no equivalent.
Impact on Property Investors
Emigrants retaining South African property are particularly affected. Monthly rental income cannot be transferred abroad until AIT tax clearance is granted by SARS, which itself requires the funds to be deposited first in a South African bank account.
“The partial change shows that SARB recognizes the October modifications caused damage. But rental income and directors’ fees should be treated like other income streams, and non-residents deserve the same annual allowance as residents. South Africa needs a rational, investor-friendly exchange control framework.
Read more here on our ongoing struggle against unhelpful exchange control bureaucracy and fairer treaetment of non-resident taxpayers:
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