The South African Reserve Bank (SARB) has released Exchange Control Circular No. 15/2025, updating the Authorised Dealer Manual. This amendment establishes a new compliance obligation for non-residents who receive specific types of income from South African sources but are not registered with the South African Revenue Service (SARS).
Under the amendment, non-residents who receive South African-sourced income—such as dividends, rental income, trust distributions, directors’ fees, or pension fund payments—and are not registered on the SARS database must now obtain a SARS Manual Letter of Compliance – International Transfer (MLC) before any funds can be transferred offshore.
Without this MLC, Authorised Dealers (typically local banks) cannot release the funds.
In practice, this change creates additional administrative steps for non-resident investors, trustees, and other recipients of South African-sourced income who are not registered taxpayers. It may also cause delays in offshore remittances, as funds cannot be released until a SARS verification-like process is completed.
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