This draft Note provides guidance on the interpretation and application of various provisions of the Act relating to foreign dividends. It discusses the current gross income inclusion, exemptions and other provisions applicable to foreign dividends.
The Note does not deal with the income tax consequences of a dividend paid by a headquarter company since this is addressed in the draft Interpretation Note issued on 12 February 2015 "Headquarter Companies”.
Interpretation Note No. 2 (Issue 3) "Foreign Dividends – Deductibility of Interest" archived on 11 February 2016 because of legislative amendments. Section 11C was repealed with effect from 1 April 2012.
Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.