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Taxation and residency

Living in South Africa: tax residency, tax brackets, inheritance and gifts

South Africa treats you as a tax resident in two ways: through a permanent residence to which you normally return, or a physical presence test, which begins after more than 91 days in the year and involves other conditions. Residents are taxed on their worldwide income, while non-residents are taxed only on their South African-sourced income. The state also levies inheritance tax of 20 % and later 25 %, and a gift tax from which non-residents are exempt.

This page is based on the South African Revenue Service (SARS) website updated between March and August 2026, with the exception of two documents: the Residency Guide (6th edition, May 2009) and the FAQ on Exemption of Overseas Employment Income (3rd edition, March 17, 2020). It does not cover social security, visas, capital gains tax rates, or termination of residency.

Two residency tests, including a six-year presence test

The SARS guide on residence, in its May 2009 edition, distinguishes between two tests.

Ordinary residence. A person is a resident if their permanent home, to which they normally return, is in South Africa.

Physical presence. This test applies annually, subject to three cumulative conditions: more than 91 days in the tax year, more than 91 days in each of the five preceding years, and more than 915 days cumulatively over those five years. The tax year runs from March 1st to the end of February. A part of a day counts as a full day.

The guide adds two exit rules. A person who became a resident through the presence test ceases to be one after at least 330 consecutive full days spent outside the country. A person who emigrates ceases to be a resident on the date of their departure. A person considered to be a resident exclusively of another country with which South Africa has a treaty relationship is excluded from the definition of "resident.".

The guide was published in May 2009, more than seventeen years ago: check that a more recent version does not change these criteria before counting your days.

Resident or non-resident: what is taxed

According to the same guide, residents are taxed on their worldwide income, subject to certain exclusions, while non-residents are taxed only on South African-sourced income. Regarding capital gains tax, the SARS page specifies that a non-resident is taxed only on real estate located in South Africa or on the assets of a permanent establishment. Indirect interests, such as shares in a real estate company, are treated as real estate.

Tax year 2027

The SARS page, updated on March 17, 2026, displays the tax year 2027, from March 1, 2026 to February 28, 2027. The "See changes" link on the page shows the date February 25, 2026.

Taxable income (rands)Tax
1 to 245,10018 % of taxable income
245,101 to 383,10044,118 + 26 % of the fraction beyond 245,100
383,101 to 530,20079,998 + 31 % of the fraction beyond 383,100
530,201 to 695,800125,599 + 36 % of the fraction beyond 530,200
695,801 to 887,000185,215 + 39 % of the fraction beyond 695,800
887,001 to 1,878,600259,783 + 41 % of the fraction beyond 887,000
1,878,601 and more666,339 + 45 % of the fraction beyond 1,878,600

For the same year, the primary rebate was 17,820 rand, and the tax threshold was 99,000 rand for a person under 65. The rebates were 9,765 rand for those 65 and over, and 3,249 rand for those 75 and over (thresholds of 153,250 and 171,300 rand, respectively).

Dividends: a tax of 20 %

The dividend tax rate is 20% for dividends paid since February 22, 2017, unless exempt or at a reduced rate. The tax applies to dividends paid by a company resident in South Africa or by a foreign company whose shares are listed on a South African stock exchange. Non-residents may benefit from a reduced rate under a tax treaty. For France, the treaty limits are detailed on our page about the Franco-South African tax treaty.

Capital gains: the annual exclusion

For the 2027 tax year, the annual exclusion for individuals increases to 50,000 rand, compared to 40,000 rand from 2017 to 2026. In the year of death, it amounts to 440,000 rand for 2027, compared to 300,000 rand from 2017 to 2026. The SARS pages consulted display their inclusion rates and the exclusion of primary residences for the years 2018 and 2019: we do not repeat them, as they are valid for the current year.

Inheritance: the estate duty

The SARS page, updated on August 19, 2026, sets inheritance tax at 20 % on the first 30 million rand of taxable value, and then 25 % thereafter. A deduction of 3.5 million rand is applied to the net value of the estate.

The tax applies to the worldwide assets of an individual who is ordinarily resident in South Africa. For non-residents, it applies to their assets located in South Africa. The page cites estate duty treaties with the United States, the United Kingdom, Zimbabwe, and the BLS countries (Botswana, Lesotho, and Eswatini). It does not mention France, and the 1993 Franco-South African treaty does not address inheritances or gifts.

Gifts: reserved for residents

The gift tax amounts to 20 % on the cumulative value of donated assets up to 30 million rand, and then 25 % on any amount exceeding that, with the cumulative calculation starting from March 1, 2018. The first 150,000 rand donated annually by an individual is exempt. A gift to a spouse is also exempt. Only residents are liable for the tax; the page states that non-residents are not.

Residents who work abroad: employment exemption

A SARS FAQ, in its March 17, 2020 edition, describes an exemption for overseas employment income capped at 1.25 million rand per tax year. This exemption requires being outside South Africa for more than 183 cumulative full days and more than 60 consecutive full days within a 12-month period. It applies only to employed tax residents. The text is six years old: reread it before citing it.

On the French side: what remains taxable

French tax residence remains valid as long as one of the three criteria is met: the home or principal place of residence, the professional activity, or the center of economic interests. Legal doctrine states: "It is sufficient that one of the criteria is met." Our page on Article 4 B provides further details.

If France ceases to be your tax residence, you are only taxed there on your French-source income, subject to the tax treaty. The minimum rates are 20% of your taxable income up to €29,579 and 30% of your taxable income above that amount for income received in 2025, with an option to use the average rate when it is more favorable. The French wealth tax (IFI) continues to apply to your real estate located in France, if your net taxable assets exceed €1,300,000 as of January 1st. As long as you are domiciled in France, you must declare annually any accounts opened, used, or closed abroad. Service-public.gouv.fr indicates a fine of €1,500 per undeclared account, increased to €10,000 per account when the country does not have a tax treaty with France: check the applicable amount for your situation.

South African inheritance tax: a numerical example (fictitious profile)

Situation. A deceased person, fictitious profile, usually resided in South Africa. His net estate is estimated at 40,000,000 rand.

Issue. His heirs want to know the order of magnitude of the estate duty.

Strategy. They deduct the allowance of 3.5 million rand, then apply 20 % to the first tranche of 30 million rand of taxable value and 25 % beyond.

Result. The taxable value is 36,500,000 rand. The tax is 6,000,000 rand on the first tranche, plus 1,625,000 rand at 25 % on the remaining 6,500,000 rand, i.e. 7,625,000 rand in total.

This profile is fictitious. The calculation ignores deductions and exemptions not detailed on the page, the conversion to euros, and the French treatment of this inheritance.

Living in South Africa: what changes depending on your situation

  • Your permanent address and the number of days you are present, year by year.
  • The nature of your income: salaries, dividends, rents, pensions, winnings.
  • Whether or not you maintain your home, your business or your economic interests in France.
  • The location of your assets and your relationship to your heirs.
  • Your gift project before or after your move.

No results are guaranteed. These points are examined case by case, with a South African professional for local law.

Frequently asked questions

How many days do you need to spend in South Africa to be considered a tax resident?

The physical presence test requires more than 91 days in the tax year, more than 91 days in each of the five preceding years, and more than 915 cumulative days over those five years. The ordinary residence test does not depend on a number of days: it focuses on permanent residence.

Are there inheritance taxes in South Africa?

Yes. According to SARS, 20 % on the first tranche of 30 million rand of taxable value, then 25 %, after a deduction of 3.5 million rand.

Does a non-resident pay gift tax?

According to the SARS page, only resident persons are liable for the gift tax.

Does a French citizen living in South Africa remain a French tax resident?

It depends on the criteria. French doctrine recognizes three criteria, but only one is sufficient. In cases of dual residency, the Franco-South African convention determines the outcome.

Take stock of your situation

The calculation of your future, the transfer of your assets, and the transition between two countries require preparation before relocating. Balmont Conseil, a firm based in Lyon for nearly 14 years, assists executives and families whose lives connect France and South Africa. Schedule an appointment to discuss your needs.

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Alexis SagnierFinancial and real estate investment advisor, insurance broker, AMF certified
Founder of Balmont Conseil, Lyon (ORIAS 13003497)

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