South African resident individuals and companies - loop
structures
Following the Minister of Finance's announcement in the 2020
Medium Term Budget Policy Statement and in order to support South
Africa's growth as an investment and financial hub for Africa,
it is advised that the full 'loop structure' restriction
has been lifted to encourage inward investments into South Africa;
subject to the normal criteria applying to inward investments into
South Africa and the reporting to the Financial Surveillance
Department.
This reform is effective from 2021-01-01 and applies to private
individuals and companies, including private equity funds that are
tax resident in South Africa.