Offshore Structures Can Be Smart—But They Must Be Compliant.
South African tax residents are subject to some of the most complex and far-reaching international tax rules in the world. If you hold interests in
foreign trusts, controlled foreign companies (CFCs), or offshore bank and investment accounts, you have significant reporting and tax obligations
under SARS.
We help you understand, manage, and stay fully compliant with these obligations—while protecting the integrity and efficiency of your offshore
structures.
Our Advisory Services Include:
SARS compliance for foreign trusts
– Disclosure of beneficial interests and distributions
– Interpretation of anti-avoidance rules (section 7C, 7(8), and 25B)
– Advice on deemed donations and attribution of income
Controlled Foreign Company (CFC) tax planning and reporting
– Determination of CFC status under Section 9D
– Calculation of net income imputed to SA shareholders
– Exemptions (e.g., high-tax and foreign business establishment exemptions)
– Assistance with SARS disclosures and annual tax return reporting
Offshore asset and account disclosure
– Reporting of foreign bank accounts, shares, crypto, and property
– Application of exchange control and tax rules
– Foreign investment allowances and tax compliance status (TCS)
Voluntary disclosure and remediation support
– SARS Voluntary Disclosure Programme (VDP) submissions
– Rectifying historic non-compliance before audits or penalties arise
Why It Matters
– Failure to comply with SARS rules around offshore interests can lead to:
– Hefty penalties and interest on undeclared income
– Double taxation if foreign tax credits or DTAs aren’t applied correctly
– Criminal liability in cases of intentional non-disclosure
– Increased audit scrutiny due to automatic exchange of information (AEOI/CRS)
Who Needs This Service?
– South African residents with shares in offshore companies or family trusts
– High-net-worth individuals with international investments or wealth structures
– Entrepreneurs using foreign companies for global operations
– Trustees or beneficiaries of offshore trusts
– Anyone with historic offshore income or assets yet to be disclosed to SARS
Stay Transparent. Stay Protected.
SARS is aggressively enforcing offshore compliance through international data sharing agreements. Our role is to ensure your structures are legally
sound, tax-efficient, and fully declared—before issues arise.
We combine technical tax expertise with deep understanding of SARS enforcement trends
We work discreetly and professionally with clients worldwide
We help you regularise and optimise your offshore structures
Protect Your Offshore Wealth—Compliantly
Let us help you manage the complexity of cross-border tax laws, avoid penalties, and take full control of your offshore position.
Book a Confidential Consultation
Talk to us about your offshore trusts, CFCs, or foreign assets—and how to handle them the right way under South African law.