I see that a company resident in SA can elect to receive dividends exempt of DWT been withheld. Is the same applicable to trusts?


Important:

This answer is based on tax law for the tax year ending 28 February 2020.

Answer:

We accept that both companies, the one declaring the dividend and the beneficial owner of the dividend, are resident in the RSA for tax purposes.  

Such a dividend will then, accepting that the required declarations were made to the company (see section 64G), be exempt from the dividends tax - see section 64F(a) of the Income Tax Act.  

Section 64F makes no provision for a dividend to be exempt from the dividend tax where the beneficial owner is a trust (Resident or otherwise). 

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