While this offers a timely opportunity, there is confusion in the market about which processes apply to which thresholds when South African tax residents move funds offshore — especially when transferring more than R10 million. This confusion can lead to missed chances.
Understanding the Limits and Approval Processes
When South African residents move money offshore it involves both the South African Revenue Service (SARS) and South African Reserve Bank (SARB), depending on the amount in question.
Familiarise yourself with the following three key thresholds:
- Up to R1 million – No SARS Clearance Needed
Any amount below R1 million per calendar year falls under the Single Discretionary Allowance (SDA) and can be externalised without approaching SARS for prior approval or tax clearance.
- Between R1 million and R10 million – SARS AIT Required
To move funds in this range allowed under the Foreign Investment Allowance, South African tax residents must obtain a SARS Approval of International Transfer (AIT) serving as a Tax Compliance Status (TCS) Pin.
Once issued, your authorised dealer (typically your bank) will automatically accept the SARS AIT and transfer up to R10 million, without having to involve SARB.
- More than R10 million – You Need SARS AIT and SARB Approval
For amounts exceeding R10 million, SARS still have to issue the AIT but applies a far more rigorous audit process. This high level of scrutiny requires a professionally prepared application from experts.
In addition, any amount above R10 million, demands a separate layer of approval from SARB’s Financial Surveillance (FinSurv) department, submitted by your authorised dealer.
In our experience, SARB approval is a mere administrative step and formality following SARS issuing an AIT Pin. In practice, we have never encountered a rejection or undue delay from SARB.
A Practical Example: SARS Clearance for R50 Million
If SARS issues an AIT Pin reflecting tax clearance for say, R50 million, you may immediately transfer R10 million abroad under the FIA. However, to transfer the remaining R40 million, you first need SARB clearance. Dealing with these cases, we find this can take typically two to three weeks, meaning clients should plan accordingly.
Apply for an AIT Before You Need It
An AIT clearance from SARS is an excellent way to ensure you are fully reconciled with SARS and ready to act should market conditions turn favourable.
We recommend that all HNWIs apply for an AIT proactively, considering the total amount they plan to externalise within the next 12 months, even if they do not intend to transfer the full funds immediately. Where an AIT Pin is valid for 12 months, it gives you flexibility in terms of timing and strategy.
In summary:
- Step 1: Obtain SARS AIT/TCS Pin.
- Step 2: Externalise the first R10 million under the FIA.
- Step 3: Apply via your bank to SARB for approval to move any excess above R10 million.
Final Thoughts: Plan Ahead to Maximise Your Offshore Strategy
Moving funds offshore does not need to be complex, but it does require careful sequencing and a clear understanding of the distinct roles of SARS and SARB. SARS confirms your tax compliance, while SARB governs how and when capital may flow out of the country.
Our team specialises in managing this process — from securing SARS clearance and liaising with authorised dealers to handling SARB FinSurv submissions.
With expert support, you can move your funds offshore efficiently, timeously, and in full compliance with South African regulations.