Understanding new compliance requirements for foreign nationals with property in South Africa

Banks have recently informed many legitimate non-resident clients that proof of tax compliance is now required before rental income can be cleared or credited into their non-resident rand accounts. Foreign nationals who ownfixed propertyin South Africa and derive rental income from it are increasingly facing new compliance hurdles when accessing or transferring those funds. Recent feedback from multiple South African banks indicates the tightening of access to non-resident bank accounts where additional tax compliance requirements are not met, which could leave foreign property owners temporarily out of pocket, says Lovemore Ndlovu, the head of the South African Reserve Bank (Sarb) Engagement and Expatriate Compliance at Tax Consulting SA.

South Africa’sproperty marketcontinues to attract strong interest from foreign buyers and non-resident foreign buyers (foreign investors). According to Lightstone, in 2024, foreign buyers accounted for 40% of all property purchases exceeding R10 million, thereby underscoring the growing appetite for high-end real estate. The proportion of non-resident foreign buyers also rose from 2.9% in 2019 to 3.7%, driven by lifestyle appeal, favourable exchange rates and attractive investment returns.

“Bank messages signal that bona fide non-resident bank accounts may soon be restricted unless additional tax compliance requirements are met. If these new compliance requirements are not met, funds received from the rental source will be placed in a non-interest-bearing suspense account before being credited into the bona fide non-resident bank account,” Ndlovu says. Tax Consulting SA says that at the centre of this issue is the Approval International Transfer (AIT) Tax Compliance Status (TCS) PIN before receiving and sending money offshore.

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This requirement has become more prominent following regulatory changes introduced by the South African Reserve Bank (SARB), effective October 23, 2025. Many bona fide non-resident clients have recently been advised by their banks that rental income cannot be cleared or credited into their non-resident rand accounts unless proof of tax compliance is provided. Banks are now requiring confirmation in one of the following forms: According to Ndlovu, the requirement has been confirmed following engagements with both SARS and SARB, who have clarified that bona fide non-resident individuals earning rental income from South Africa are now subject to AIT TCS PIN requirements, even where the income was previously regarded as freely remittable.

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