South Africa and its worldwide tax regime : have we (almost) come full circle?

Some significant amendments to South Africa's worldwide tax regime at the end of 2003 effectively incorporated a participation exemption in relation to foreign dividends and capital gains where the South African resident holds more than 25% of the equity of the foreign company. Coupled with the relevant exemptions in relation to controlled foreign companies, it is entirely possible that foreign-source active income will escape the South African tax net completely.