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South Africa: Indirect interests in foreign company through foreign trust

South Africa: Indirect interests through foreign trust

Proposed changes to the controlled foreign company (CFC) rules would address instances when a South African resident individual has an indirect interest in a foreign company through a foreign trust.


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The 2017 changes to the CFC rules dealt with the issue of South African resident companies having an indirect interest in a foreign company through foreign trusts, but not individuals. In an attempt to close the loophole in the current tax law regarding the use of foreign trusts to defer tax or re-characterise the nature of income, amendments are proposed in the 2018 Taxation Laws Amendment Bill. Comments are due by 16 August 2018.


Read a July 2018 report [PDF 106 KB] prepared by the KPMG member firm in South Africa

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