International tax planning considerations for South African emigrants

Fernandes, Orlando Jose

International tax planning considerations for South African emigrants

Master Thesis

1990

Abstract

The purpose of this paper is to outline the international income tax implications facing a South African emigrant. The discussion that follows is based on an individual or family emigrating from South Africa to Australia. The reason why I have chosen Australia is because I have a detailed knowledge of the domestic tax laws in Australia. The thought process that I have followed applies equally to most other western countries. The reason for this is because Australia's income tax system is based on residence principles which are similar to most other western countries. On the other hand, South Africa's tax laws are based primarily on source principles, a feature which is applicable mainly to tax havens (but for the high rate in South Africa). I will commence firstly by giving a brief overview of the income tax system in Australia. I will then proceed to discuss the income tax consequences of a flow of dividends and interest out of South Africa, and into Australia. I will then attempt to raise alternative structures which will provide a more effective after-tax return to the individual or family who settles in Australia.