Non-residents of South Africa are subject to tax on income derived from a source in South Africa. SA branches of foreign companies are not considered to be separate legal entities for tax purposes, and no tax is withheld on transfers of profits to the head office. Branches of foreign companies are taxed at a rate of 28% (for tax years ending before 31 March 2023) and are not liable for dividends tax or any branch profits repatriation tax. The CIT rate is reduced to 27% for tax years ending on or after 31 March 2023.
Note that a branch must register as a taxpayer and submit tax returns. Separate financial statements must be drawn up for the SA branch. For all practical purposes, the SARS will treat the branch as a separate entity. For example, inter-branch cost recoveries levied by the head office incurred in the production of SA income normally will be allowed as a deduction by the branch, although this treatment is not extended to interest on inter-branch loans.
In terms of DTAs, the taxation of branches is limited to cases where the branch constitutes a PE.
FAQs
Branches of foreign companies are taxed at a rate of 28% (for tax years ending before 31 March 2023) and are not liable for dividends tax or any branch profits repatriation tax. The CIT rate is reduced to 27% for tax years ending on or after 31 March 2023.
What is the corporate income tax in South Africa? ›
The corporate tax rate in South Africa is a flat rate of 27% for all companies. However, trusts (excluding special trusts) in South Africa pay tax at a separate rate of 45%. Additionally, companies are subject to a capital gains tax (CGT) of 21.6%.
What is the branch tax in South Africa? ›
Branch tax
The ITA imposes a tax at 28% (reduced to 27% for tax years ending on or after March 31, 2023) of South African sourced after-tax profits earned by a branch of a non-resident company.
What is the difference between a branch and a subsidiary in South Africa? ›
For the purpose of this article a subsidiary is a separately registered South African company in which a Foreign Company holds shares. A branch, on the other hand, is not a separate legal entity and could be considered a South African 'office' or 'division' within the Foreign Company.
What are the income groups in South Africa? ›
According to Maphupha (2018) , the income categories (in South African Rand, ZAR) were defined as poor (0 -54 344), low emerging middle (54 345 -151 727), emerging middle (151 728 -363 930), realized middle (363 931 -631 120) and upper middle 631 212 -863 906) [34]. ...
How much foreign income is tax free in South Africa? ›
The answer depends on the amount of remuneration you earn for the services rendered outside South Africa. If the amount of your remuneration is R1,25 million or less, the full amount will be exempt from normal tax in South Africa, provided the amount relates to services rendered outside South Africa.
What is corporate taxable income? ›
The corporate tax rate is a tax levied on a corporation's profits, collected by a government as a source of income. It applies to a company's income, which is revenue minus expenses.
How are branches taxed? ›
How is the Branch Profit Tax Calculated? The branch profits is calculated by first determining the dividend equivalent amount for the year. This is generally defined as the corporation's after-tax net ECI that is not reinvested in a U.S. business (and thus is treated as though the funds were repatriated.
How is a foreign branch taxed in South Africa? ›
Branches of foreign companies are taxed at a rate of 28% (for tax years ending before 31 March 2023) and are not liable for dividends tax or any branch profits repatriation tax. The CIT rate is reduced to 27% for tax years ending on or after 31 March 2023.
What is the difference between a branch and a subsidiary? ›
Here are the main differences between a subsidiary and a branch: A subsidiary is a separate legal entity fully or partially owned by another company, whereas a branch is simply an extension of the parent company. The subsidiary reports to the holding company, whereas the branch reports to the head office.
A branch office is a location, other than the main office, where a business is conducted. Most branch offices consist of smaller divisions of different aspects of the company such as human resources, marketing, and accounting.
Why set up a branch instead of a subsidiary? ›
Compared to setting up a subsidiary, establishing a branch is often less complex and time-consuming. The parent company retains full control over the branch's operations, ensuring consistency with overall business strategy.
What is a branch corporation? ›
A branch office, on the other hand, is a direct extension of the parent company and can engage in core activities like sales and contracts. It is designed to help generate revenue for the company and serves a particular geographic region. Critically, however, it is not a separate legal entity from the parent company.
What salary is considered rich in South Africa? ›
The data reveals that you would need to make about R151 451.00 per month to be in the top 1% of earners. In terms of overall wealth, one would require a net worth of about R4. 2 million to be a member of South Africa's top 1%.
What is the income divide in South Africa? ›
The top 20 percent of the population holds over 68 percent of income (compared to a median of 47 percent for similar emerging markets). The bottom 40 percent of the population holds 7 percent of income (compared to 16 percent for other emerging markets).
Is R10,000 a good salary in South Africa? ›
The Bureau for Economic Research (BER), in its latest report on consumer confidence, regarded a household with earnings of between R5,000 and R20,000 per month as a middle-income household. BER regarded households with monthly earnings above R20,000 as high-income households.
How much must a business make to pay tax in South Africa? ›
The Turnover Tax system is a single tax system and replaces Income Tax, VAT, Provisional Tax, Capital Gains Tax and Dividends Tax. Qualifying businesses will declare and pay one (1) tax (unless with a VAT or PAYE option) and only start paying tax when their annual turnover exceeds R335 000.
What is the income tax rate in South Africa? ›
The tax rates range from 18% to 45%, applied to different income brackets. The tax rate in the personal income tax table below may be shown as an amount, a percentage rate, or a combination of both.
What is the turnover tax in South Africa? ›
Turnover Tax is a simplified system aimed at making it easier for small businesses to meet their tax obligations. It replaces Income Tax, VAT, Provisional Tax, Capital Gains Tax and Dividends Tax for small businesses with a qualifying annual turnover of up to R1 million.
What is the capital gains tax for a company in South Africa? ›
The inclusion rate (only 40% of the capital gain will be taxed if you're an individual, and 80% if it's a company or trust selling the property). The tax rate. As of February 2024, the marginal tax rate is 18% for individuals, 21.6% for businesses, and 36% for other trusts.