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The South African Reserve Bank Financial Surveillance Department has introduced changes to the exchange control requirements for income remittances to non-residents, including dividend remittances.
Background
On 22 October 2025, the South African Reserve Bank Financial Surveillance Department (SARB) issued Exchange Control Circular No 15/2025 (Excon Circular 15/2025) detailing amendments to section B.3 of the Currency and Exchanges Manual for Authorised Dealers (Manual). The changes relate to the treatment of income remittances to non-residents, one of them being in respect of dividend remittances/transfers.
Click here for Excon Circular 15/2025. The updated Manual (dated 28 October 2025) can be found here.
Key changes to dividend remittances/transfers
The changes to section B.3(B)(i) of the Manual introduce a requirement for the non-resident shareholder to obtain tax clearance from SARS.
This changes the previous regime, under which non-resident shareholders whose shares were endorsed non-resident were generally entitled to receive dividend remittances/transfers without any further requirements.
The relevant extract reads as follows:
"(b) Authorised Dealers may allow the transfer of dividends distributed by a South African company, provided the following is obtained from SARS:
(aa) if the beneficiary is not registered on the SARS registered database, a Manual Letter of Compliance - International Transfer; and
(bb) if the beneficiary is registered on the SARS registered database, a TCS – AIT PIN."
Scope of the changes
It is important to note that the above requirements have not been imposed in respect of the remittance of interest.
However, the same requirements have been imposed on, among others, the payment of directors' fees.
Companies should consider the impact of the new requirements on income transfers, particularly dividend remittances to non-resident shareholders.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
