For years, many South Africans living abroad have operated under the radar, moving rental income, pension income, or interest out of the country with minimal red tape. However, a significant shift in South African Revenue Service policy and the exchange control regulations has ended this “era of ease”. If you reside abroad and have not yet formalized your tax position, your South African assets and your global financial privacy could be at risk.
Although the Approval of International Transfer (AIT) certificate has technically existed for some time, its impact was previously limited.
Historically, non-residents could expatriate South African-sourced income using a simple Tax Clearance Certificate for “good standing” based on older exchange control rules. This is no longer sufficient.
The Exchange Control Manual has been specifically updated to mandate the AIT certificate for fund transfers, explicitly replacing the “good standing” requirement based on the latest Exchange Control Manual from 13 March 2026. This change has triggered a wave of enforcement, with South African banks freezing the accounts of individuals who attempt to move funds without this specific clearance, which we have seen happens very quickly in practice.
The most critical hurdle for many expats is that an AIT application is not only a form; it is a comprehensive audit of your tax health. Before SARS will even consider issuing an AIT:
- All returns must be submitted. Every outstanding tax return from previous years must be filed and up to date.
- Your SARS profile must be entirely “green”. Any outstanding administrative penalties, old debts, or missing information will lead to an immediate rejection of your transfer request.
SARS uses the AIT application as a “gatekeeper” to ensure all historic tax obligations are met before any capital leaves the country.
The scope of the SARS review during an AIT application depends entirely on your registered tax residency status. This is where many South Africans abroad face the greatest risk:
- If you are registered as a non-resident for tax purposes, SARS limits its review to your South African-sourced funds only.
- If you are still registered as a tax resident, SARS maintains a mandate to review your worldwide funds and assets.
If you reside abroad permanently but have not “ceased” your tax residency on the SARS system, you are technically still a resident in its eyes. Applying for an AIT in this state invites SARS to scrutinize your global income and foreign assets, potentially leading to unforeseen risk on money earned entirely outside of South Africa.
If you have done nothing about your South African tax status since moving abroad, you are likely sitting on a compliance time bomb:
- You may find yourself unable to access your own money in South Africa when you need it most.
- You risk granting SARS a window into your international financial life.
- Trying to fix years of non-compliance in a rush to move funds is significantly more difficult and costly than proactive management.
The AIT process is the new reality of South African exchange control. For South Africans abroad, the message is clear: proactive compliance is the only way to protect your assets. Ensuring your residency status is formalized and your tax returns are up to date is no longer optional, it is a prerequisite for financial freedom across borders.
Reinert van Rensburg is a tax attorney and Jonty Leon is managing partner at the Leap Group.
Disclaimer: The views expressed in this article are those of the writers and are not necessarily shared by Moonstone Information Refinery or its sister companies. The information in this article does not constitute legal or tax advice that is appropriate to every individual’s needs and circumstances.
