Pretoria · South AfricaWONE Global Partner · South Africa
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South Africa × Tax & International Structuring
Tax & International Structuring in South Africa
Tax and structuring for businesses, investments and deals that cross borders. In South Africa, that means local law, local regulators and local practice, handled by a qualified professional who practises there.
Who handles this work
On request
WONE Global can find the right Tax & International Structuring professional in South Africa for you.
No WONE Global Partner holds this yet. Send us your requirement: WONE Global confirms whether a vetted Associate firm can act, tells you who it is and checks for conflicts before any work begins.
Bring a requirement →South Africa at a glanceAfrica
Johannesburg · Tuesday 3 November
21:08
Local time
- Currency
- ZAR
- Working week
- Monday – Friday
- Dialling code
- +27
- Region
- Africa
What the rules say in South Africa
Tax & International Structuring, the essentials
From the South Africa market guide: the points that matter most for tax & international structuring, each with the source it was checked against.
Essentials guide · Source-checked research100% of statements checked against a source54 checked against an official source0 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed
The corporate income tax rate for companies is 27 percent.
Years of assessment ending between 1 April 2026 and 31 March 2027. Small business corporations and companies in approved Special Economic Zones have separate rates.South African Revenue Service (SARS) · checked 2026-10-19VAT is levied at the standard rate of 15 percent on supplies of goods and services by registered vendors.
Zero-rated and exempt supplies apply under the Value-Added Tax Act, 1991.South African Revenue Service (SARS) · checked 2026-10-19VAT registration is compulsory where taxable supplies exceed R2.3 million a year, and voluntary registration is available above R120,000, up from R1 million and R50,000 respectively.
Thresholds announced in Budget 2026 to take effect from 1 April 2026.South African Revenue Service (SARS) · checked 2026-10-19Dividends tax is a final tax of 20 percent on dividends paid by resident companies, withheld by the paying company, and may be reduced for non-residents under a tax treaty.
Exemptions apply, for example for resident companies receiving dividends.South African Revenue Service (SARS) · checked 2026-10-19A final withholding tax of 15 percent applies to South African-source interest and to the gross amount of royalties paid to non-residents.
Non-resident recipients; treaty relief and statutory exemptions may reduce or remove the tax.South African Revenue Service (SARS) · checked 2026-10-19The Global Minimum Tax Act, 46 of 2024, is deemed to have come into operation on 1 January 2024 and imposes a top-up tax under an Income Inclusion Rule and a Domestic Minimum Top-up Tax.
Constituent entities of in-scope multinational groups as defined by reference to the OECD GloBE Model Rules; fiscal years beginning on or after 1 January 2024.South African Revenue Service (SARS) · checked 2026-10-19Employers pay a skills development levy of 1 percent of total remuneration, but the levy does not apply to employers whose annual remuneration is under R500,000.
South African Revenue Service (SARS) · checked 2026-10-19Companies operating in approved Special Economic Zones may qualify for a 15 percent corporate income tax rate.
Qualifying companies in approved SEZs only; conditions apply.South African Revenue Service (SARS) · checked 2026-10-19
Read the full guide: Tax, accounting and reporting · Licensing, incentives and sector rules
Scope
What the service covers here
- 01Review the proposed cross-border structure
- 02Identify direct and indirect tax exposures
- 03Consider withholding, treaty and transfer-pricing issues
- 04Coordinate implementation across the relevant jurisdictions
Key questions
What we will work through with you
- What needs to be decided before tax & international structuring work starts?
- Who is professionally responsible in each country?
- Which other work, such as tax or employment, must happen at the same time?
- What information and decisions are needed from the business?
If your work involves another country or another area of expertise, WONE Global brings in the right professional and keeps all advisers informed.
WONE Global Partners in South Africa
Professionals working here
No named lead for Tax & International Structuring yet — these WONE Global professionals already work in South Africa and can bring the right local colleague in.
Pretoria · South AfricaAlso in South Africa
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Cases
What clients bring to Tax & International Structuring
The cases this service leads or joins, each with what is at stake, how WONE Global handles it and who handles it in South Africa.
Urgent We've received a tax notice from another country. Do we have to pay?Tax assessments, disputes & managementUrgent We sell online to customers abroad. Do we have to register for their VAT or GST?Tax assessments, disputes & managementUrgent Tax was deducted abroad and again at home. Can we get it back?Payments, FX, digital assets & treasuryUrgent The tax authority wants our transfer pricing documentation. We don't have any.International tax planning & transfer pricingWhat tax filings do we have to make in each country, and when?Tax assessments, disputes & managementHow should we price and invoice customers abroad so we actually get paid?Contracts, commercial disputes & collectionsAt what point do our sales abroad mean we need a local company?International tax planning & transfer pricingShould we reorganise how our regional business is run?International tax planning & transfer pricingCan we centralise finance, HR or IT in one country?International tax planning & transfer pricingHow do we move cash between our companies in different countries?Payments, FX, digital assets & treasury
WONE Global Intelligence
Ask about tax & international structuring in South Africa
Ask in your own words. Answers come from WONE Global's checked records, with every source shown, and end with the named Partner who can act. Go deeper on any point, or build a decision file.
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