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.