For many South Africans, offshore investments, companies and trust structures form an important part of their long-term financial planning. These structures are often established to facilitate international investment, protect family wealth, provide succession planning solutions, global diversification of assets, or support international business activities. While considerable time and effort are usually invested in designing and establishing an offshore structure, many individuals overlook an equally important aspect, which is ensuring the structure remains appropriate and effective over time.

An offshore structure should never be viewed as something to set up and forget about. Circumstances change, legislation evolves, and family and business objectives often shift significantly over the years. A structure that was perfectly suited to an individual’s needs when it was established may no longer deliver the same benefits or remain fully compliant in today’s regulatory environment. As a result, regular reviews have become an essential component of responsible offshore investing and wealth planning.

A well-conducted health check assesses whether the structure remains aligned with the personal circumstances, family dynamics, business interests, tax position, and long-term objectives. It also evaluates whether the structure is being properly administered, governed, and maintained in accordance with both local and international requirements.

With increased global transparency, information-sharing agreements between jurisdictions, beneficial ownership reporting obligations, and changing tax frameworks, ongoing reviews are no longer a best-practice exercise. They are increasingly becoming a necessity.

For South Africans with offshore structures, exchange control considerations should form part of any regular review. While many individuals focus on tax and investment performance, the movement of funds abroad between South Africa and offshore jurisdictions remains an important compliance consideration.

Failing to consider exchange control requirements can result in reporting discrepancies, delays in transactions, increased scrutiny from financial institutions, and potential regulatory complications.

A review should consider the source of funds used to establish or fund the structure, how funds have moved between South Africa and offshore jurisdictions, whether distributions have been appropriately reported, and whether future transactions remain aligned with current regulatory requirements.

Being mindful of exchange control helps ensure that offshore structures operate efficiently, that banking and investment arrangements remain sustainable, and that future wealth, succession, and investment portfolio planning can be implemented.

Regular reviews ensure that structures remain fit for purpose and continue to support the objectives for which they were originally established.

Certain events often indicate an immediate review such a change in tax residency, significant growth or changes in investment holdings or new business activities that differ from the original purpose.

The key question for offshore structures is no longer whether their structure was established correctly, but whether it continues to serve its intended purpose today. For offshore investment, South Africa typically favour offshore structures such as Mauritius, Guernsey, Isle of Man, Switzerland, UAE or even UK and Singapore, a review not only provides peace of mind but also helps identify risks, inefficiencies, and opportunities before they become costly, ensuring that offshore structures continue to protect and preserve wealth for future generations.

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Few founders wake up thinking about corporate structures. Most are focused on building products, acquiring customers, hiring talented people, refining their offering and, for many, raising capital. Yet when discussions with potential investors begin, the conversation often moves surprisingly quickly beyond the product itself. Common questions include:

• Where is the company incorporated?
• Who owns the intellectual property?
• Is there a holding company?
• How will future investors invest in the business?
• Can the existing structure support expansion into multiple countries?

For many founders, this can seem like an unexpected shift in focus. After all, shouldn’t investors be more interested in the product than the paperwork?

In practice, investors are assessing more than the commercial opportunity. They are also evaluating whether the business can accommodate investment, protect shareholder interests and support future funding rounds or an eventual exit. As a result, corporate structure often becomes an important part of investment discussions much earlier than many founders anticipate.

Having worked with founders, investors and professional advisers across multiple jurisdictions, one recurring theme often emerges: a compelling business model may attract investor interest, but an ill-considered corporate structure can create unnecessary friction during due diligence and fundraising discussions. Structure rarely determines whether a business succeeds, but it can influence how efficiently investors assess risk and deploy capital.

Question 1: Can we invest in this efficiently?

One of the first considerations for many international investors is how straightforward it will be to invest in the business.

Established corporate jurisdictions generally provide legal frameworks, governance standards and shareholder protections that investors, lawyers and institutional funders have encountered before such as Limited Liability Companies, Sole Proprietorships or Joint Ventures . Familiarity with business type can reduce legal uncertainty, simplify due diligence and make subsequent investment rounds more efficient.

This helps explain why conversations around holding company jurisdictions have become increasingly common across the African startup ecosystem. Venture capital commentary frequently highlights Delaware as a popular jurisdiction for companies seeking US investment. For businesses operating across multiple African markets, Mauritius is increasingly discussed as a jurisdiction that offers a familiar legal environment, extensive treaty networks and a platform from which regional expansion can be coordinated.

This does not suggest that one jurisdiction is universally superior to another. Rather, the appropriate structure depends on factors such as the target investor base, operating markets, regulatory environment and long-term growth strategy. However, for founders building businesses with a pan-African footprint, Mauritius often features in early structuring discussions due to its longstanding role as an international financial centre focused on facilitating cross-border investment into Africa.

Question 2: Who owns the business’s most valuable assets?

For many technology businesses, the company’s greatest value lies beyond its certificate of incorporation.

Instead, investors often focus on assets such as:

• Proprietary software and source code
• Intellectual property
• Trademarks and brands
• Customer data
• Proprietary systems and processes

During due diligence, investors commonly examine whether ownership of these assets has been properly documented and legally assigned to the company. Unclear ownership can delay investment, reduce valuation or create complications during future fundraising or an acquisition.

For this reason, founders are often encouraged to establish clear documentation around:

• Intellectual property assignments
• Software ownership
• Trademark registrations
• Domain ownership
• Contractor and employee agreements
• Licensing arrangements

Addressing these matters early is generally simpler than trying to resolve them during a live investment process.

Question 3: Can the right business structure support growth across borders?

Many successful African startups begin by solving a local problem before expanding into neighbouring markets or serving customers internationally.

African startups often face structural considerations that differ from businesses operating within a single large domestic market. A company may develop technology in one country, employ talent across several jurisdictions, serve customers regionally and raise capital from investors based in Europe, North America, the Middle East or Asia. As businesses expand, structures that were originally established for local operations may need to evolve to accommodate broader commercial and investment objectives.

This is one of the reasons why international holding company jurisdictions are often considered by growth-stage African businesses. In some cases, founders explore Mauritius-based holding structures to help centralise governance, facilitate future investment and create a platform capable of supporting expansion across multiple jurisdictions.

As businesses grow, their corporate structures may also need to evolve. Expansion into multiple jurisdictions can introduce additional considerations relating to governance, regulatory compliance, taxation and operational management.

Depending on the business model, founders may eventually need to consider:

• Local subsidiaries
• Cross-border governance
• Currency management
• Future fundraising requirements
• Shareholder rights
• Regulatory compliance across multiple jurisdictions

Rather than focusing solely on current operations, investors often consider whether the existing structure is capable of supporting the company’s long-term ambitions without requiring significant restructuring at a later stage.

Question 4: Will future investors view the structure favourably?

Fundraising is rarely a single event.

A business that raises seed capital today may later seek Series A funding, growth capital or investment from institutional investors, private equity firms or development finance institutions. Each stage often introduces more extensive due diligence and increasingly sophisticated governance expectations.

For this reason, legal advisers and venture capital practitioners frequently encourage founders to think beyond the immediate funding round. A structure that works well for early-stage investors may require adjustment as the business matures.

Planning ahead can reduce the need for complex restructuring at the point when a significant investment opportunity arises.

Question 5: What is the best business structure to support my strategy?

There is no universally “correct” corporate structure for every startup.

A founder targeting Silicon Valley venture capital may face different structural considerations from a founder building a regulated fintech business or expanding into multiple African jurisdictions. Likewise, software companies serving global customers may have different requirements from businesses operating primarily within a single domestic market.

The objective is not to adopt a particular jurisdiction because it has become fashionable. Instead, the corporate structure should align with the company’s commercial objectives, regulatory obligations, funding strategy and plans for future growth.

Corporate structure is most effective when it supports the business strategy, rather than dictating it.

Startup due diligence

Industry discussions around Delaware, Mauritius and other international holding company jurisdictions are ultimately part of a broader conversation about investment readiness.

While no single jurisdiction is appropriate for every business, discussions around Delaware, Mauritius and other international holding company jurisdictions reflect a broader objective shared by founders and investors alike: creating structures that support scalability, governance and long-term investment readiness. For businesses with regional ambitions across Africa, Mauritius is frequently considered because of its established legal framework, international business ecosystem and historical role as a gateway for investment into the continent.

While revenue growth, market opportunity and product innovation remain central to investment decisions, due diligence commonly extends to areas such as:

• Corporate governance
• Ownership of intellectual property
• Shareholder protections
• Scalability of the legal structure
• Regulatory compliance
• Future exit options

For many founders, structuring discussions feel premature when product development, customer acquisition and fundraising are competing for attention. Yet investors often view structure as part of the broader investment-readiness assessment. Understanding these considerations early can help founders avoid unnecessary complexity later and position their businesses to engage more confidently with future investors, strategic partners and advisers.

Founders do not necessarily need sophisticated international structures from day one. However, understanding the questions investors are likely to ask and considering whether the existing structure supports future growth, investment and expansion can save considerable time, cost and complexity as the business evolves.

Sources and Further Reading

This article draws on publicly available commentary and guidance relating to venture capital investment, corporate structuring and African startup ecosystems, including:

1. Zunaid Lundell, Where Should Founders in Africa Set Up Their Holding Company? Why Mauritius Could Be the Answer? (2023).
2. LaunchPad, VC-Friendly Corporate Structures for African Startups (2026).

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There is a particular kind of quiet that settles over South Africans living abroad, the one that arrives at a braai in a park somewhere in London or Perth or Dubai, when someone mentions the smell of fynbos after rain, spotting pinguins off the coast of Cape Town, or the way the light falls on the Drakensberg in the late afternoon. For many, the pull eventually becomes a decision – returning home.

It is a deeply personal choice, and for high-net-worth individuals who have spent years or sometimes decades building wealth outside South Africa, it is also a structurally complex one. The question is not simply whether to return, but how, and in what order.

In my work with returning South Africans and their professional advisers, many returnees experience reverse culture shock upon returning to South Africa and often wish they had considered certain things, prior to the move home. The most common mistake I see is the emotional decision being made first and the financial decision being made second. By the time many clients sit down with us, they have already moved back, and some of the most effective planning windows have quietly closed.

Residence based tax system

South Africa operates on a residence based tax system. Once you are ordinarily resident in South Africa, which is determined not by a calendar but by where your life is centred, you become subject to South African tax on your worldwide income. This is a material shift for someone who has been living and earning abroad, particularly if their current jurisdiction imposes little or no personal income tax.

The implications extend beyond income. South Africa levies estate duty at 20% on the dutiable value of an estate up to R30 million, and 25% above that threshold. Executor fees can add a further 3.5% of the gross estate value before VAT. For a returning South African with offshore assets, offshore wealth, property in multiple countries, and family structures established abroad, how those assets relate to their South African estate becomes a first-order priority.

What to do before you get on the plane

The planning window that precedes a return to South Africa is often the most valuable and the most underused. Several actions can only be taken with maximum effectiveness while you remain tax resident elsewhere.

If you hold assets in an offshore trust, foundation, or holding company, the terms of those structures, the jurisdiction in which they sit, and your relationship to those entities all need to be examined before your tax residency status shifts. Once you become a South African tax resident, tax implication mean that certain deemed disposal rules, controlled foreign company (CFC) provisions, and exchange control regulations begin to apply. A structure that served you well abroad may require amendment before you return, not after the fact. So, review your offshore structures while you still can.

Moving capital between jurisdictions is significantly more straightforward when you are not yet a South African resident. The South African Reserve Bank (SARB) exchange control framework governs what residents can externalise and under what conditions. Bringing capital into South Africa as a non-resident can often be structured more cleanly, with clearer remittance records that carry real weight later, for estate purposes, for South African Revenue Service (SARS), and for the integrity of your overall position.

Coordinating your wills across every jurisdiction is super important. This is one of the most consistently overlooked steps in the pre-return process. A will drafted in the UK may not be automatically effective in South Africa, and vice versa. If you hold assets in multiple countries, you likely need jurisdiction-specific wills that are coordinated. For families returning with minor children, this becomes even more important. Guardianship designations contained in a document that a South African court will not recognise are designations that may not hold when they matter most.

What still matters after you arrive from living abroad

In my experience, some of the most consequential decisions are made or missed, in the first 12 to 18 months back in South Africa, when structures are still adjustable and tax positions are still being established.

Holding assets offshore as a South African resident is entirely legal, but the basis on which those assets are held, the income they generate, and the disclosures required by SARS must be handled with care. Maintaining the legitimacy of your offshore assets therefore requires active management. Failure to properly disclose offshore income or assets is a serious compliance risk under South Africa’s exchange control and tax laws. It falls to the taxpayer to get this right, and ignorance of the requirement is not a defence SARS has shown much patience with.

Many returning South Africans hold pension assets in the UK, Australia, or the UAE built up over years of working abroad. These retirement and pension assets held abroad deserve specific attention. The tax treatment of those assets, both in the originating country and in South Africa, varies significantly depending on the country involved, any applicable double tax agreement (DTA), and the nature of the fund itself.

Cover taken out abroad may lapse on your return, be denominated in a foreign currency that creates ongoing mismatch risk, or exclude certain exposures that are specific to life in South Africa. Rebuilding a coherent risk and life cover portfolio takes time. It should begin early, not when a gap emerge.

The role of the right adviser

No two returning South Africans look the same. The appropriate approach for a family returning from the UAE, where foreign earnings were subject to no income tax and assets were accumulated freely, differs materially from the situation facing someone returning from the UK, where pension contributions, ISAs, and property ownership all carry their own tax histories. In the UK, rental income is taxed in South Africa if resident.

The jurisdiction in which offshore assets currently sit, the family’s ties to other countries, future travel and investment intentions, and the full composition of the estate all feed into the analysis before any structural recommendation is made.

At Sovereign Trust (SA), we work with returning clients and their existing professional advisers, attorneys, accountants, and financial planners, to review the full picture before and after the move. We are in the business of making sure that whatever structure a client holds or needs actually fits their life. My contact details are below. This conversation needs to happen well before the return flight is booked.

This article is intended for general information purposes only and does not constitute financial, tax, or legal advice. Individuals should seek independent professional advice tailored to their specific circumstances before making any structural or tax decisions in connection with a return to South Africa.

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SARS has announced the filing dates for the 2026 tax season which will open 13 July 2026. We remind all clients that, as tax residents, you are required to declare your worldwide income, not just amounts earned locally in South Africa. This includes earnings from foreign employment, investments, rental income, and any offshore structures. For those taxpayers who choose (or have previously chosen) not to disclose, this decision will not be without consequences. Why?

SARS is using the data it receives under the Standard for Automatic Exchange of Financial Account Information in Tax Matters – more commonly known as the Common Reporting Standard (CRS) – to gather information on the offshore assets of South African tax residents.

CRS, developed by the OECD at the start of 2014, calls on countries to obtain financial account information on non-residents from their financial institutions (banks, investment companies and corporate service providers). These institutions then report to their local tax authorities who in turn automatically exchange that information with tax authorities in other countries on an annual basis.

By 2025, 123 countries carried out automatic exchange of information, South Africa being one of these countries. More than 123 million accounts worth €12 trillion were reported already. Over 2,700 bilateral exchange relationships existed in 2025.

Automatic exchange of information is a game changer for tax authorities. This system of multilateral exchange is providing countries around the world with a wealth of new data, empowering their revenue authorities to ensure that offshore accounts, interest earned and payments from structures are being properly declared and when its is not, they still have the information to enable them to tax their residents accordingly.

Since 2019 SARS has been issuing notices to South African taxpayers based on information it has received from foreign jurisdictions under the CRS. The system is clearly working. These notices inform taxpayers that, in the interests of administrative justice, SARS intends to initiate a review of their tax affairs. It asks them to confirm that they have offshore assets and requests detailed information as to the location, the amount and the nature of the investments.

If there is any uncertainty about your reporting and tax obligations in relation to any international structures in which you have an interest, we suggest that you contact your nearest Sovereign office to discuss your arrangements and the need for obtaining tax advice, says Sovereign Trust (SA) Director Coreen van der Merwe.

If you have undisclosed offshore assets and you have not yet received a SARS notice, it would be irresponsible to think that you have fallen through the cracks of the system. It is best to be pro-active and discuss the need for a VDP application with a tax advisor. This might protect you against criminal prosecution and tax penalties. Also remember that your interest in the offshore structure might be of such a nature that no reporting to SARS is required. If you have any uncertainty, speak to an expert.

We also suggest that any South African taxpayer who is currently contemplating setting up any new international structure should ensure that they are working with a reputable management company that has an understanding of the local reporting and tax issues, and which will also be able to connect you with a tax advisor in the jurisdiction where you are tax resident.

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South Africa’s 2026 Budget, delivered by Finance Minister Enoch Godongwana on 25 February, signals a period of relative fiscal stability after several years of pressure on public finances, writes Ralph Wichtmann, Managing Director of Sovereign Trust (SA).

Government debt is expected to peak and gradually decline as fiscal consolidation gains traction, while economic growth is forecast to improve moderately over the next few years.

This shift was best illustrated last November, when South Africa secured its first credit rating upgrade in nearly 20 years after S&P Global raised the country’s foreign-currency long-term sovereign rating from ‘BB-‘ to ‘BB’. It cited stronger growth prospects, an improving fiscal outlook and reduced contingent liabilities following better performance at state power utility Eskom.

The other really positive news is that South Africa was officially removed from the Financial Action Task Force (FATF) ‘grey list’ of jurisdictions under increased monitoring last October. The removal recognised South Africa’s progress in strengthening its anti-money laundering and counter-terrorism financing (AML/CFT) frameworks to address the 22 deficiencies identified by the FATF in February 2023.

South Africa is widely regarded as being one of the most significant financial hubs on the African continent. With that comes the expectation that it should meet international standards of governance, oversight and transparency in respect of financial matters.

South African Budget

For South African tax residents with international assets or those considering externalising capital, the Budget did not introduce sweeping new tax measures. However, several updates and policy signals remain highly relevant for offshore structuring, wealth planning and estate strategies. Below are the key implications for clients:

1. No major tax increases – but continued reliance on a narrow tax base

One of the most notable developments is that the previously proposed ZAR20 billion tax increase was withdrawn due to stronger-than-expected revenue collections. At the same time, the National Treasury highlighted the structural reality that a relatively small group of high-income taxpayers contributes a significant portion of South Africa’s tax revenue.

For internationally mobile individuals and families with global wealth, this reinforces a long-standing planning consideration:

• South African tax residents remain taxed on worldwide income and gains.
• Effective international tax planning and asset structuring remains essential.

2. Tax incentives to encourage Investment and Savings

The Budget introduced several measures to encourage domestic investment and savings, including increasing the annual limit for tax-free investment accounts from ZAR36,000 to ZAR46,000 and retirement fund deduction limits were also increased to ZAR430,000 annually.

The Capital Gains Tax (CGT) annual exclusion for individuals is to increase from ZAR40,000 to ZAR50,000 and the CGT exclusion in respect of the disposal of a primary residence is also to increase from ZAR2 million to ZAR3 million. The threshold for exemption from Donations Tax applicable to individuals, will increase from R100 000 to R150 000.

While these measures primarily support domestic savings, they highlight a broader government objective; strengthening South Africa’s investment culture. For high-net-worth families, this reinforces the importance of balancing:

• Onshore tax-efficient vehicles (retirement funds and tax-free investments), and
• Offshore investment structures for diversification and currency risk management.

3. Implications for South Africans with International Income

The Budget reiterates the central importance of tax residency in determining tax obligations.

• South African tax residents are taxed on worldwide income.
• Non-residents are taxed only on South African-sourced income and assets.

For individuals living abroad or planning to emigrate, this distinction remains one of the most important planning considerations. Key areas that requiring careful planning include:

• Timing of tax residency cessation.
• Exit Tax implications of becoming non-resident.
• Structuring foreign income streams through appropriate entities.
• Ensuring compliance with exchange control and tax reporting obligations.

4. Estate Planning and Trust Structures

South African trusts continue to play a central role in wealth planning but remain subject to a relatively high tax rate of 45%. This reinforces the need for careful structuring when trusts are used in cross-border estate planning. Key considerations include:

• Whether a South African trust or offshore trust is more appropriate.
• The role of foreign beneficiary structures.
• The interaction between CGT, Donations Tax and Estate Duty
• Whether assets should be held through offshore companies that are owned by trusts.

International families should also consider the impact of:

• Controlled Foreign Company (CFC) rules.
• Anti-avoidance provisions.
• Tax reporting obligations.

5. Exchange Control and Capital Externalisation

One of the major Budget changes introduced in relation to exchange control rules is the increase in the Single Discretionary Allowance from ZAR1 million per calendar year to ZAR2 million with no tax clearance needed. It should be noted, however, that the Foreign Investment Allowance, which requires SARS Approval for International Transfer (AIT) tax clearance, remains unchanged at ZAR10 million per year. These allowances remain the primary mechanisms for legally externalising capital.

For wealthy families, capital externalisation strategies typically involve:

• Phased transfers of investment capital offshore.
• Offshore trusts or Family Investment Companies (FICs).
• Diversification of custody, banking and asset management.

6. Increased focus on Financial Transparency and Compliance

South Africa’s removal from the FATF grey list was a key milestone and the government has indicated that continued strengthening of AML/CFT frameworks remains a priority. South Africa’s next FATF mutual evaluation is scheduled to begin in the first half of 2026, with the assessment concluding in October 2027. This Fifth Round evaluation will be assessing the sustainability of South Africa’s reforms. For globally mobile families, this is likely to involve:

• Increased reporting obligations.
• Greater scrutiny of cross-border transactions.
• Continued emphasis on increased tax transparency.

The Common Reporting Standard (CRS) was first published by the OECD in 2014 as the global standard for automatic exchange of financial account information. It was designed to promote tax transparency and help tackle offshore tax evasion. Over 100 jurisdictions worldwide have implemented the CRS and most of those have now been exchanging information since 2018.

This year, global tax transparency has been fundamentally expanded by bringing crypto assets, digital money and enhanced due diligence into automatic exchange regimes under the new CRS 2.0 and the Crypto-Asset Reporting Framework. From 2026, financial institutions and crypto service providers must report broader asset classes, transaction-level data and additional client identifiers, closing long-standing reporting gaps and significantly increasing cross-border tax visibility.

This expansion makes compliant structuring more important than ever. For internationally active South African families, the focus therefore remains clear – robust global structuring combined with long-term flexibility.

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The Financial Action Task Force (FATF), the international anti-money laundering watchdog, removed South Africa from its ‘grey list’ of countries following a successful on-site review of its Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) regime in July.

The delisting reflects comprehensive reforms implemented since 2023, including expanded regulation under the Financial Intelligence Centre Act, enhanced beneficial ownership transparency, stricter reporting obligations and improved enforcement capacity.

South Africa was placed on the grey list in February 2023 after the FATF identified significant weaknesses in its anti-money laundering and counter-financing of terrorism framework. These included gaps in enforcement, transparency around beneficial ownership and asset recovery processes.

The FATF welcomed South Africa’s significant progress in strengthening the effectiveness of its AML/CFT regime to meet the commitments in its 22-point Action Plan by:

• Demonstrating a sustained increase in outbound Mutual Legal Assistance (MLA) requests that help facilitate ML/TF investigations and confiscations of different types of assets in line with its risk profile.
• Improving risk-based supervision of Designated Non-Financial Businesses & Professions (DNFBPs) and demonstrating that all AML/CFT supervisors apply effective, proportionate and effective sanctions for non-compliance.
• Ensuring that competent authorities have timely access to accurate and up-to-date Beneficial Ownership (BO) information on legal persons and arrangements and applying sanctions for breaches of violation by legal persons to BO obligations.
• Demonstrating a sustained increase in law enforcement agencies’ requests for financial intelligence from the Financial Intelligence Centre (FIC) for its ML/TF investigations.
• Demonstrating a sustained increase in investigations and prosecutions of serious and complex money laundering and the full range of TF activities in line with its risk profile.
• Enhancing its identification, seizure and confiscation of proceeds and instrumentalities of a wider range of predicate crimes, in line with its risk profile.
• Updating its TF Risk Assessment to inform the implementation of a comprehensive national counter financing of terrorism strategy.
• Ensuring the effective implementation of targeted financial sanctions and demonstrating an effective mechanism to identify individuals and entities that meet the criteria for domestic designation.

As part of a comprehensive reform programme, the South African government passed the General Laws (Anti-Money Laundering & Combating Financial Terrorism Financing) Amendment Act 2022 and the Protection of Constitutional Democracy Against Terrorism & Related Activities (POCDATARA) Amendment Act in December 2022.

These addressed 15 of 20 deficiencies relating to the adequacy of laws and legal frameworks that were identified in the mutual evaluation report. Further actions then undertaken to address deficiencies include:

• Expanding the scope of accountable institutions under the Financial Intelligence Centre (FIC) Act 38 of 2001 to bring crypto-asset service providers and high-value goods dealers into scope.
• Strengthening beneficial ownership transparency through amendments to the Companies Act 71 of 2008 and launching the Companies & Intellectual Property Commission’s Beneficial Ownership Register, which requires the disclosure of interests of 5% and above and blocks annual returns without prior BO filings.
• Improving enforcement capacity through increased funding for the Directorate for Priority Crime Investigation (DPCI) – generally known as the ‘Hawks’ – and the National Prosecuting Authority.
• Imposing stricter reporting obligations under sections 28 and 29 of the FIC Act, including cash threshold reporting and suspicious transaction reporting.
• Amending the Prevention & Combating of Corrupt Activities Act 12 of 2004, including the creation of a new offence for the failure to prevent corrupt activities by private companies and state-owned entities.

South Africa must continue to work with the FATF and Eastern & Southern Africa Anti-Money Laundering Group (ESAAMLG) to sustain the improvements in its AML/CFT system.

“South Africa’s progress in addressing the AML/CFT deficiencies and exiting the FATF grey list is a significant achievement,” said Sovereign South Africa Ralph Wichtmann. “But it is only the start of a broader process to continue to strengthen key institutions, improve enforcement and governance processes, and to ensure that these improvements are maintained.

“The FATF delisting will result in reduced compliance, increased access to global banking services and a more straightforward basis for cross-border transactions. But businesses and investors will also be required to maintain robust risk-based compliance programmes, ensure accurate beneficial ownership disclosures and perform enhanced due diligence for high-risk transactions.”

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The Isle of Man is famous for many things, but nothing defines it quite like the TT: a motorbike race so fast, so technical, and so unforgiving that even veteran riders describe it as a test of absolute precision. With more than 200 corners being navigated at speeds exceeding 320km/h, the TT has earned its reputation as the most dangerous motorcycle race in the world.

Yet just beyond the roar of the engines, the island presents an entirely different side; one defined by security, structure, and stability rather than risk. And it is this quieter, more predictable side that is catching the attention of globally minded South Africans looking to grow and preserve their wealth for generations to come.

A stable structure in a volatile world

An Isle of Man discretionary trust is built on a robust foundation. It begins with a settlor who has the intent to create a trust, a clearly identifiable trust asset and a corporate trustee that assumes legal ownership on behalf of beneficiaries. “This structure is designed to endure,” says Coreen van der Merwe, Director at Sovereign Trust (SA), a company specialising in setting up offshore companies and trusts around the world. “It offers continuity and protection even when personal circumstances change.”

Beneficiaries do not own the assets; they only have the hope of benefiting. This distinction, combined with the island’s well-established trust laws, makes the structure attractive for high-net-worth individuals seeking long-term planning solutions.

Layered on top of that is the Isle of Man’s tax environment: 0% income tax, no capital gains tax, no inheritance tax, and no withholding tax on distributions. Compared to the tax environment of the United Arab Emirates, this might not be too different, however, many South Africans plan on moving back to South Africa at some point and this is when these benefits become really valuable.

Why more South Africans are looking to ‘man up’

Key advantages of setting up a trust in the Isle of Man include the preservation of wealth for future generations without the fragmentation that often occurs after death, as well as seamless succession planning that avoids the delays and costs associated with multi-jurisdictional probate and international executor fees. Trust structures also provide robust asset protection from potential creditors, business risks, or relationship breakdowns, while ring-fencing assets such as farms, holiday homes and business interests that cannot be easily subdivided. In addition, they support minor or vulnerable beneficiaries through tailored provisions and create a clear separation between personal and business assets, offering both clarity and long-term protection. Timing is particularly important and ideally the trust should be set up before the settlor/founder of the trust has returned to South Africa and/or has become SA tax resident again. When a person gets the timing right, assets transferred to the trust will be ringfenced from South African taxes even when distributions are received from the trust in the future.

An additional, and often overlooked, benefit is the local expertise available on the island. “Many Isle of Man trust administrators, lawyers and accountants are themselves South African,” notes Van der Merwe. “This dual perspective is truly invaluable. They understand both the regulatory requirements and the cultural nuances that shape South African wealth planning.”

Setting up a trust: what South Africans living in the UAE must know

Establishing a trust offshore is not a quick, one-step exercise. It requires careful planning and professional guidance, particularly because South Africans must navigate South African Reserve Bank and Revenue Service requirements in addition to The Isle of Man’s legal framework.

The process includes:

• Consulting a cross-border specialist who understands dual tax residency, controlled foreign company rules, and exchange control.
• Choosing the most appropriate trust structure, usually a discretionary trust.
• Reviewing and signing the trust deed, which outlines trustee powers, beneficiaries and the trust’s purpose.
• Transferring an initial asset, which formally activates the trust. Without this transfer, the trust does not exist in law.
• Transfer assets to the trust before you become South African tax resident.

Once established, the trust can hold global investments, property, portfolios, and other international assets, in strong currencies like GBP, USD, and EUR.

For South Africans with global wealth ambitions, the Isle of Man offers a jurisdiction with decades of stability and a legal system built for long-term security, Van der Merwe emphasises that success in offshore structuring depends on expertise, not experimentation.

“Just as the TT demands absolute precision and risk mitigation, so does cross-border wealth planning. An offshore trust should give you peace of mind, not uncertainty and working with professionals who understand South African realities as well as offshore rules is the only way to achieve that.”

For more details, contact Coreen van der Merwe below.

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South African farmers are no strangers to resilience. Year after year, they face unpredictable weather, rising input costs and shifting global market conditions; but they push through the dirt to deliver world-class produce to markets across the globe.

South Africa’s agricultural export market continues to grow, cementing the country’s position as a major player globally. In Q1 2025, exports reached USD3.36 billion, a 10% increase from the same period in 2024.

Yet as South Africa’s export footprint expands, many farming businesses are beginning to ask an important question: how can we structure our growth to make the most of these international opportunities safely, efficiently and for the long term?

According to Brandon Voges, business development manager at Sovereign Trust (SA), the answer lies in offshore structuring – and not just as a tax strategy, but as a holistic business growth solution. Offshore investment vehicles, such as trusts, companies and family office structures, established in a jurisdiction that offers regulatory, tax and administrative benefits enable you to preserve and grow your wealth internationally while continuing to reside in South Africa.

Thinking beyond borders

When your produce crosses borders, so does your business. Offshore structuring through reputable jurisdictions such as Mauritius or Guernsey allows farmers to position their operations for global expansion while maintaining strong ties to their South African roots.

Arranged correctly, an offshore structure can help farmers in the following ways:

• Protect export income and reinvest profits offshore for future growth.
• Access international finance to expand distribution networks and enter new markets.
• Manage foreign exchange efficiently.
• Build long-term succession and wealth plans that secure the family legacy for future generations.

However, offshore success depends on more than location. It depends on understanding the unique realities of South African farming and integrating them with compliant, practical international structures.

Key considerations

Too often, offshore advice is disconnected from the everyday realities of farming — from seasonal cash flow cycles to export regulations and family business dynamics.

1. Compliance and confidence

Offshore expansion doesn’t mean stepping outside the rules – it means knowing how to work within them strategically. With increasing scrutiny from the South African Revenue Service (SARS) and global regulators, obtaining qualified tax, exchange control and transfer pricing advice is essential. Sovereign’s structures are designed to be transparent, compliant and efficient, ensuring farmers can grow with confidence while meeting every regulatory requirement on both sides of the border.

2. Securing the family legacy

For many farmers, the business is also the family’s most valuable asset. Offshore planning creates opportunities to structure this wealth for succession, investment and protection. Through collaboration with wealth management specialists, families can ensure their offshore assets and investments are managed in a way that aligns with their broader estate and succession planning goals, giving peace of mind that what they have built will endure.

3. The financial ecosystem that supports growth

Offshore success requires the right financial infrastructure. Farmers expanding abroad should consider working with forex and financing partners who understand the agricultural industry’s unique timing, risks and capital requirements. From foreign exchange management to cross-border financing, having a partner that understands the rhythm of farming can make the difference between opportunity and obstacle.

Bringing it all together

At Sovereign Trust we believe that offshore success is not built on one element alone. It’s about the synergy between structuring, tax and transfer pricing compliance, wealth management and financial strategy.

Through our global office network, our professional teams can draft trust deeds, incorporate companies, and create director or shareholder agreements that meet both South African and offshore requirements. We can also then provide the ongoing support in administering, managing and reporting to ensure your structure remains in good standing with local and international regulators.

By working with a South African-led team that understands the agricultural mindset and combines it with world-class offshore expertise, farmers can build structures that don’t just save costs, they create opportunity.

This is about planting the seeds for a future where South African farming businesses can grow beyond borders, with confidence, clarity and control.

The post Planting seeds for global growth: why South African farmers should be thinking ‘offshore’ appeared first on The Sovereign Group.

Global strategies, lasting legacies.

YOU ARE FORMALLY INVITED TO ATTEND THE SOVEREIGN TRUST

2025 RETIREMENT AND WEALTH STRUCTURING SEMINAR

In today’s evolving financial landscape, lasting legacies require more than traditional planning – they demand global insight and forward thinking strategies.

Join us for an exclusive seminar as we explore the latest in wealth and retirement structuring, global trends, and key regulatory updates alongside our expert sponsors.

Click here to read and download the Midrand agenda

Click here to read and download the Cape Town agenda

DATE
Tuesday 23 September 2025 (Midrand)
Thursday 25 September 2025 (Cape Town)

TIME
Registration at 08h00 Conference running from 09h00 to 16h15 Sponsor Exhibition from 16h15 to 17h00

VENUE
Tuesday – Courtyard Hotel, Waterfall City Midrand
Thursday – Southern Sun Newlands Cape Town

Please Note: The Cape Town event is now at full capacity but there are still a few places left on the Midrand event.

If you would like to RSVP for Midrand, please contact Mandi Diener.

The post 2025 Sovereign Trust SA Wealth and Retirement Structuring Seminar appeared first on The Sovereign Group.

South Africans can start with one basic certainty: nothing in the South African Income Tax or Reserve Bank regulations prohibits South African nationals from opening a bank account, investment account or setting up a trust overseas.

Opening an offshore account or setting up an offshore trust is a prudent financial strategy because it provides currency protection against rand depreciation, helps to diversify your investments and allows access to a far greater range of investment opportunities.

Personal circumstances will dictate the timing, but opening an offshore bank account will typically be a practical and helpful move long before you’ve build up significant wealth to justify setting up an offshore trust. Once the decision has been made to go offshore, the next question is how to do it as quickly and cost effectively as possible.

When should you open an offshore bank or investment account?

We are finding that many South Africans have international transactional needs for both business and personal reasons, yet some are only aware of one-dimensional foreign currency accounts, often referred to as Customer Foreign Currency (CFC) accounts. This type of account allows the account holder to manage foreign receipts and payments through their local bank, but it is all subject to Exchange Control regulations.

In comparison, an offshore bank account will enable South African accountholders to conveniently receive payment for work done outside of the country, make international payments and to access international funds by way of a debit, credit or prepaid card. From here the funds can be transferred to a variety of different investment accounts, also based offshore.

While there may not be any tax liability in the jurisdiction where the account is being held, accountholders will typically still be taxable in South Africa in respect of any interest or capital gains that are earned on the account because South Africa imposes taxation on worldwide income.

South African residents are required to declare all income and assets in foreign accounts. The Common Reporting Standard (CRS) is a global information sharing regime designed to provide tax authorities with information regarding financial accounts held by local taxpayers outside of their country of tax residence. The account details, balances and interest earned will therefore automatically be shared with the South African Revenue Service (SARS).

South Africa also has strict exchange control regulations that may limit the amount of money you can transfer from South Africa or hold in foreign currency. It is therefore essential to consult a tax advisor for guidance on complying with these obligations.

In opening an offshore account, there are a number of factors to bear in mind:

• Some international banks require significant minimum deposits.
• Foreign accounts often incur high service fees, monthly charges and transaction fees.
• Required documents will include proof of identity (typically your passport), proof of address and, in some cases, financial references.
• Some banks may require applicants to open an account in person, while others are comfortable to work through a licensed service provider like Sovereign Trust, in which case, a face to face meeting will not be required.
• Some jurisdictions are identified as ‘high-risk third countries’ by organisations like the Financial Action Task Force (FATF), requiring financial institutions to apply Enhanced Due Diligence (EDD) measures to all customers, both new and existing, who are established in those countries.

When does it make sense to set up an offshore trust?

At what point should you consider setting up a trust to house the funds in your offshore bank or investment account and why? Although many of the tax benefits that were associated with trusts have been eroded by anti-tax avoidance legislation in recent years, they can still offer great advantages in the following areas:

• Preservation of your assets and legacy for future generations.
• Estate and succession planning solutions that can help to avoid lengthy and expensive probate procedures
• Enhanced asset protection in respect of potential creditors, litigation or marital breakdowns.
• Look after the needs of minor or disabled beneficiaries (special trusts).
• Ensuring your beneficiaries benefit from an asset that cannot be easily subdivided, such as a holiday house or farm.
• Separation of personal capital assets from business and trading assets.
• Provide for dependents and relatives who are incapable of managing their money or taking care of their own affairs.

If you intention is to achieve any or a combination of these goals, setting up a trust and investing in the trust’s name, may be an option. You will first need to ensure that setting up an offshore trust is cost effective.

You will need to consider the annual trustee fees (which will depend on the jurisdiction, the type of trust and also the activity levels of the trust), the amount available to invest, as well as the possible returns that can be achieved.

Corporate trustees provide a professional service that is simple and easy to use. They will carry out trust administration – the trust reporting, tax returns, accounts and registration – whilst ensuring the settlor’s and the beneficiaries’ interests are balanced appropriately.

Licensed corporate trustees must adhere to certain standards and meet various statutory obligations. They are also impartial and discreet. Importantly, they can serve as a neutral party in the event of a dispute by considering the views of all parties in equal measure.

As an absolute minimum requirement, the trust’s returns should cover the annual trustee and other annual costs associated with the trust and investment. Trust fees in Mauritius are typically the lowest, starting at USD2,000 per year.

There are a number of different countries worldwide that have enacted trust legislation but the quality and suitability of that legislation can vary. When selecting the best jurisdiction for establishing a trust it is important that it should offer:

• A strong tradition of enforcing trusts
• An English common law system
• An established reputation for trust business
• Modern legislation, including contemporary trust concepts
• Low or no taxation for trusts.

Some jurisdictions are not recommended due to legal or political uncertainties or because their courts or professionals have limited trust experience. Some jurisdictions have not kept pace with the modern trust legislation or are unsuitable because of high tax regimes.

Sovereign generally recommends that trusts are established in Cyprus, Gibraltar, Guernsey, Hong Kong, the Isle of Man, Malta, Mauritius and Singapore. Sovereign is fully licensed to act as professional trustees in all these jurisdictions.

It should also be remembered that the practical advantages of a trust are gained from the distinction that is drawn between the legal owner of property, the trustee, and those people that have the use or benefit of the property, the beneficiaries.

It is vital that the trustee remains independent and exercises proper control over the trust property. A trust may be deemed to be invalid if the settlor continues to exercise power over the trust assets by retaining benefit or control, or by giving directions to the trustees. You will therefore need to have complete confidence in your trustees.

By Coreen van der Merwe, director at Sovereign Trust (SA) Limited

The post When is the right time for South Africans to go offshore with their money? appeared first on The Sovereign Group.

Growth in Sub-Saharan Africa (SSA) is projected to edge up from 3.3% in 2024 to 3.5% in 2025 and further accelerate to 4.3% in 2026–27, according to the World Bank’s most recent regional economic update.

The World Bank said the SSA was showing some resilience, despite uncertainty in the global economy and restricted fiscal space. The median inflation rate had declined from 7.1% in 2023 to 4.5% in 2024. Countries rich in resources and those facing fragility, conflict and violence were growing more slowly than others, and the region was struggling to create enough good jobs.

Africa, it said, could also pave the way to inclusive growth by investing in its human potential. Over the next three decades, the region will experience the fastest increase in the working age population of all regions, with a projected net increase of 740 million people by 2050. Up to 12 million youth will enter the labour market across the region every year in the coming decades, but only about three million new formal wage jobs are currently created each year.

As the economies in the region recover at a faster pace in the years to come, policy should be geared toward sharing the growth benefits more equally across the population by investing in human capital, fostering economic diversification and fostering jobs-friendly economic growth.

About 464 million people in the region were still living in extreme poverty in 2024 but the per capita growth acceleration expected in 2025 to 2027, at an annual average rate of 1.8%, would contribute to a modest decline in the poverty rate. Limited investments in income-generating sectors for the poor, lingering effects of past inflation, and the probable reduction of donor aid budgets worldwide pose a challenge for poverty reduction.

The post World Bank projects accelerating growth for Sub-Saharan Africa appeared first on The Sovereign Group.

The South Africa Revenue Service (SARS) is intensifying its efforts to recover tax debts from South Africans across the board as part of a new initiative, known internally as ‘Project AmaBillions’, after the government failed to win sufficient support for its proposal for a rise in VAT.

Targeting revenues of ZAR2.006 trillion for the 2025/26 fiscal year, SARS plans to onboard up to 500 new employees initially to enhance its capacity to tackle undisputed tax debts. It is aiming to recuperate an estimated ZAR70 billion to significantly offset the forecasted ZAR75 billion shortfall cited by the National Treasury over the medium term.

SARS Commissioner Edward Kieswetter has repeatedly stressed the importance of a dedicated compliance programme to trace and address over five million unsubmitted returns, focusing on individuals who are above the income threshold but remain unregistered for tax purposes.

This focus on existing tax debts is viewed as a preferable alternative to imposing new taxes within an already fragile economic environment, with the overarching aim of bolstering state resources through diligent tax compliance and recovery efforts. SARS’s compliance initiatives generated ZAR301 billion in the 2024/25 fiscal year, a 16% increase in revenue.

The post South Africa Revenue Service recruits to focus on recovering tax debts appeared first on The Sovereign Group.