South Africans who have moved abroad are facing new rules when trying to move money out of the country.
These changes mainly affect people who still earn income in South Africa, such as dividends from shares, rental income, or directors’ fees.
At the end of October 2025, the South African Revenue Service (SARS) and the South African Reserve Bank (SARB) introduced changes that reinforce the country’s capital controls.
This means offshore transfers can only happen if both SARS and SARB requirements are fully met and in the correct order.
“Even if you emigrated years ago, your money may be stuck in South Africa if your paperwork doesn’t meet the new rules,” warned Tax Consulting SA.
Under the updated rules, banks, known as Authorised Dealers, cannot send dividends or other income offshore until SARS confirms the individual’s non-resident status and that their tax affairs are up to date.
The consulting firm noted that for non-residents still registered with SARS, the process now requires two key approvals.
First, a Notice of Non-Resident Tax Status confirms that the individual has ceased being a South African tax resident.
Second, a Tax Compliance Status – Approval for International Transfer (AIT) PIN verifies that taxes are up to date.
“The AIT process, introduced by SARS in April 2023, now aligns with SARB procedures, creating a clear step-by-step path for offshore transfers,” Tax Consulting SA explained.
For individuals who are no longer registered with SARS, a Manual Letter of Compliance (MLC) is required.
This serves as a substitute for the AIT PIN and is the only way for non-residents without an active SARS profile to get clearance for international transfers.
“In essence, banks must be satisfied that the sender is tax compliant before any funds can leave South Africa,” said Tax Consulting SA.
This requirement is not limited to dividends. It also applies to other South African-sourced income, such as rental income or director’s fees.
Major compliance burden
There is some uncertainty over whether SARS will issue one MLC per individual or require a new clearance for each transaction. Banks may interpret these rules differently, adding to the administrative burden.
Previously, non-resident share certificates alone were enough to transfer dividends offshore.
Now, even with “non-resident” endorsements on share certificates, an MLC or AIT PIN is still needed. Additionally, shares must comply with South African exchange control rules.
Regulation 14 of the Exchange Control Regulations requires that shares belonging to non-residents be officially endorsed as “non-resident” by an Authorised Dealer.
Without this, banks cannot legally remit dividends, even if SARS clearance has been granted.
“Despite previous announcements suggesting exchange control rules were easing, these changes show that compliance requirements are stricter than ever,” noted Tax Consulting SA.
Many non-resident shareholders face common issues: missing non-resident endorsements, incorrect SARS residency records, or banks refusing transfers until documentation is updated.
The consequence is simple: dividends and other income could remain in South Africa indefinitely if both SARS and SARB requirements are not met.
With SARS’ December closure approaching, delays in applying for clearance could mean funds are trapped until the new year.
Non-resident shareholders expecting year-end dividends should start the process immediately. SARS’ increased enforcement makes this even more critical.
In November, a media release highlighted SARS’ litigation against Sasfin Bank Limited, where the High Court confirmed that SARS can hold banks accountable for facilitating the unlawful export of funds.
Commissioner Kieswetter warned institutions to go beyond a narrow compliance response and actively manage risks in offshore transfers.
Tax Consulting SA advised that the process for non-resident South Africans is now substantially more involved.
Shareholders should expect a full SARS residency verification, a tax compliance review, and a review of all historic share certificates to ensure proper SARB endorsement before receiving an AIT PIN or MLC.
“If you are receiving dividends or other income from South Africa, confirm your SARS and SARB compliance before your next distribution. Otherwise, your bank may delay or reject the transfer,” Tax Consulting SA cautioned.
