IOC Law / Africa Intelligence / South Africa

Taxation in South Africa

← Back to the South Africa guide

South African companies are generally taxed on worldwide income, subject to the Income Tax Act and applicable treaties; non-residents are generally taxed on South African-source income and attributable permanent-establishment profits. A cross-border business should assess residence, source and permanent establishment before deciding that it can sell into South Africa without local tax exposure.

The standard corporate income tax rate is 27% for years of assessment ending on or after 31 March 2023 and remains the operative headline rate in 2026. CIPC-registered companies are automatically registered for income tax through the CIPC-SARS interface, according to the SARS corporate income tax page. The company must still establish eFiling access, registered-representative authority and filing processes.

VAT is charged at 15%. From 1 April 2026, compulsory registration generally applies where taxable supplies exceed or are expected under a written contractual obligation to exceed R2.3 million in a consecutive 12-month period. Voluntary registration begins at R120,000 subject to the statutory conditions. SARS’s VAT registration guidance also contains special rules for foreign suppliers of electronic services. Determine whether supplies are standard-rated, zero-rated, exempt or outside scope before quoting prices or issuing invoices.

Other material issues can include dividends tax, withholding tax on interest and royalties, capital gains, employees’ tax, unemployment insurance, skills development levy, transfer pricing, controlled foreign company rules, interest limitation, reportable arrangements, customs and excise, transfer duty and securities transfer tax. Treaties may modify some withholding and permanent-establishment outcomes, but relief depends on the facts, residence evidence and procedural requirements.

Related-party arrangements for funding, management, technology, IP, procurement or distribution need defensible pricing and written terms. The accounting treatment, VAT, withholding, customs value and exchange-control record should be consistent. Before launch, register required tax products, configure invoices and payroll, identify filing owners and build a calendar for provisional tax, annual returns, VAT, PAYE and other declarations.

Tax incentives are conditional. Approved Special Economic Zone companies may qualify for a preferential 15% corporate rate where the statutory requirements are met. Do not assume location in or supply to an SEZ is enough; confirm the company, activity and approval conditions.