South Africa's headline corporate income tax (CIT) rate is 27.
The headline personal income tax (PIT) rate is 45.
The standard VAT/GST (or equivalent consumption tax) rate is 15. Registration thresholds, zero-rated and exempt categories, and reduced rates vary by jurisdiction - see the source link below for the full detail on this jurisdiction.
South Africa applies two tests. The "ordinarily resident" test (a common-law concept) treats someone as resident if South Africa is the country to which they naturally and habitually return - their real home. Failing that, the Physical Presence Test applies: an individual becomes resident if present in South Africa for more than 91 days in the current tax year, more than 91 days in each of the preceding five tax years, and more than 915 days in total across those five years - all three conditions must be met, and residency then begins from the start of the sixth year. A resident who spends a continuous 330+ days outside South Africa ceases residency from the start of that absence, triggering a deemed disposal (exit charge) of worldwide assets.
Under Section 9D of the Income Tax Act, a foreign company is a Controlled Foreign Company where South African residents collectively hold more than 50% of its participation or voting rights. The CFC's net income is attributed proportionally to South African resident shareholders and taxed in their hands, whether or not distributed. Key exemptions include: a 10% de minimis rule (a resident holding under 10% of participation/voting rights, together with connected persons, is excluded), the Foreign Business Establishment exemption (a genuinely staffed and equipped fixed place of business conducting the CFC's primary operations outside South Africa), and the High Tax Exemption - if the CFC's foreign tax is at least 67.5% of the tax it would have paid as a South African resident, its net income is not imputed.
South Africa abolished its former 3:1 safe-harbor debt-to-equity ratio for years of assessment beginning on or after April 1, 2012. Capitalization is now tested purely on an arm's-length basis under South Africa's general transfer pricing rules (Section 31) - both the quantum of debt and the interest rate must reflect what an independent lender would have provided; interest disallowed on this basis can be recharacterized as a dividend subject to dividends withholding tax.
South Africa maintains the largest double tax treaty network in Africa, with 79 tax treaties, including 28 with European countries alongside extensive coverage across Southern, North, West, and East Africa. The current authoritative list of agreements and protocols is maintained by the South African Revenue Service (SARS).