The South African Reserve Bank’s Financial Surveillance department recently issued Exchange Control Circular No. 15/2025 (‘the Circular’), which introduces important changes that directly impact how non-residents and individuals who have ceased tax residency may transfer income abroad. On evaluation, these amendments streamline certain processes, introduce stricter requirements for others, and place SARS compliance at the centre of all outbound transfers. For non-resident property owners, understanding these changes is imperative to avoiding delays and ensuring that transfers are processed lawfully and efficiently.
Notable changes to income transfers
The Circular amends section B.3 of the Authorised Dealer Manual. While many provisions remain unchanged, several practical adjustments now govern the transfer of income, such as dividends, rental income, trust distributions, pensions, annuities, and other recurring receipts.
Pension and annuity transfers
Residents temporarily abroad may continue to receive pensions and compulsory annuities, including living annuities. Importantly, non-residents and individuals who ceased South African tax residency may transfer pension and annuity income offshore without the need to obtain an annual tax compliance status (‘TCS’) of good standing. Instead, authorised dealers may rely on IRP5/IT3(a) certificates or payment advices showing the applicable tax codes. Notably, confirmation is required only once – either when the contract begins or at the first payment following the update of this rule.
Transfers of other income by residents temporarily abroad
Any income not specifically provided for must now fall under the single discretionary allowance (‘SDA’) and/or foreign capital allowance (‘FCA’). This shifts many miscellaneous income transfers into the standard individual allowances framework.
Dividends paid to non-residents
According to the Circular, authorised dealers may transfer dividends if SARS provides either:
- A Manual Letter of Compliance – International Transfer (for unregistered beneficiaries); or
- A TCS – AIT PIN (for beneficiaries registered on the SARS database).
Similar requirements now apply to several other income categories.
Trust distributions
Distributions from testamentary or inter vivos trusts may be transferred, provided two conditions are met:
- The beneficiary is a non-resident or has ceased South African tax residency; and
- SARS has issued either a Manual Letter of Compliance or a TCS – AIT PIN.
Rental income
Transfers of rental income now require the submission of:
- A copy of the rental or rental pool agreement;
- Confirmation from the client that the income is reasonable relative to the property value; and
- SARS compliance documentation (Manual Letter or TCS – AIT PIN).
Salaries and professional fees
Authorised dealers may transfer salaries or fees paid to bona fide non-residents and individuals who have ceased tax residency.
Clarifications for residents temporarily abroad
Residents temporarily abroad may receive pensions, compulsory annuities, gifts, and loans as permitted, but any other foreign currency transfers require prior written approval from the Financial Surveillance Department.
How STBB can assist you or your clients
In the context of exchange control, the Circular introduces notable changes affecting how non-residents navigate transferring income abroad. At STBB, our Non-Resident Services department is available to assist both non-resident sellers and purchasers with exchange control and tax-related services, including SARB approvals, the repatriation of proceeds from the sale of property, and applying for SARS tax directives to reduce the amount of withholding tax payable by non-resident sellers. For expert legal guidance, contact info@stbb.co.za to speak with a specialist attorney today.
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