On 17 May 2021, the South African Revenue Service (SARS) issued an update Interpretation Note 93 (Issue 3) on the taxation of foreign dividends. This Note provides guidance on the interpretation and application of various provisions of the Act relating to foreign dividends. The Note does not deal with the income tax consequences of a dividend paid by a headquarter company, since this topic is addressed in Interpretation Note 87 “Headquarter Companies”.
This Note reflects the income tax and tax administration legislation (as amended) at the time of publication and includes the following:
• The Taxation Laws Amendment Act 23 of 2020 which was promulgated on 20 January 2021 (as per Government Gazette 44082).
• The Tax Administration Laws Amendment Act 24 of 2020 which was promulgated on 20 January 2021 (as per Government Gazette 44082).
• The Rates and Monetary Amounts and Amendment of Revenue Laws Act 22 of 2020 which was promulgated on 20 January 2021.
