Page 39 - GA Maclachlan Tax Guide 2024

Capital transactions
Proceeds from the sale of assets in South Africa, may be remitted abroad�
Proceeds on the sale of assets by emigrants will be subject to the blocked
account provisions�
Dividend payments to non-residents
Dividends declared by companies are remittable to non-resident shareholders
in proportion to percentage shareholdings, subject to certain restrictions if the
dividend is declared by an affected person who has local financial assistance� An
emigrant shareholder will be entitled to dividends declared out of income earned
from normal trading activities after the date of emigration� Non-listed companies
have additional requirements to be met in order to transfer such dividends�
Dividends declared out of capital gains, or out of income earned from normal
trading activities prior to the date of emigration, remain subject to the blocked
account provisions�

Director fee payments to non-residents
Authorised dealers may transfer director’s fees to non-resident directors
permanently domiciled outside South Africa, provided the application is
accompanied by a copy of the resolution of the board of the remitting company,
confirming the amount to be paid to the beneficiary�
Ceasing to be a resident
When a person ceases to be a resident, certain tax consequences are triggered�
A trust or natural person that ceases to be a resident must be treated as having
disposed of all their assets for market value immediately before they ceased to
be a resident�
A company that ceases to be a resident will also be treated as having disposed
of all its assets for market value immediately before it ceased to be a resident� In
addition the company will be deemed to have paid a dividend on the difference
between the market value of all the shares of the company and the contributed
tax capital of the company�

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