SARS Now Allows One Annual AIT Application for Non-Residents
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If you act for a non-resident who earns income from South Africa, the process for transferring certain recurring income offshore has just become simpler.
SARS updated its Guide to the Tax Compliance Status (TCS) functionality on eFiling to clarify that certain non-residents making multiple transfers of rental income or director’s fees during the year only need to submit one Approval for International Transfer (AIT) application. The updated SARS guide has an effective date of 28 August 2026. The AIT is part of SARS's Tax Compliance Status functionality on eFiling.
SARS explains that the AIT functionality was introduced following the changes to the exchange-control framework relating to international transfers. Practitioners should therefore use the updated SARS guide when preparing AIT applications for affected non-resident clients. The annual application is based on the estimated annual value of the relevant rental income or director’s fees.
Who does this apply to?
The SARS update applies to non-resident directors and non-residents earning rental income who make multiple transfers of these amounts during the year.
For example, the income may be transferred offshore in instalments rather than as a single annual payment.
The updated SARS guidance provides for one annual AIT application in these circumstances.
This should be distinguished from the position of South African tax residents. The SARS announcement specifically refers to non-resident directors and non-residents earning rental income.
What has changed?
Previously, recurring transfers could result in multiple AIT applications during the year. SARS has now confirmed that a single annual AIT application may be submitted based on the estimated annual value of the relevant income. The change applies to:
Director’s fees; and
Rental income.
The application must still be supported by the relevant documentation. SARS describes the change as following amendments to the Exchange Control Regulations introduced by the South African Reserve Bank (SARB).
What documents are required?
The relief is on the number of applications, not on the evidence. To get one annual approval, the application must be properly built:
For director's fees:
The appointment letter, and
Confirmation from the company that PAYE is being withheld.
For rental income:
The rental contracts, lease agreements or rental statements, showing the duration, the rental amounts and the payment frequency.
The estimate is the pressure point. Approval is based on the estimated annual value, so the estimate needs to be defensible and drawn from the lease or the appointment terms, not guessed.
The annual estimate
The change does not remove the AIT requirement, it only changes how recurring transfers of specified income can be dealt with.
For affected non-residents, one annual AIT application can now cover multiple transfers of rental income or director’s fees during the year, based on the estimated annual value. That should reduce the administrative burden associated with recurring transfers while retaining the requirement for appropriate supporting documentation.
What should practitioners do?
Practitioners dealing with non-resident clients should update their AIT procedures accordingly. There are a few practical steps to take.
Identify affected non-resident clients.
Review clients who receive South African rental income or director’s fees and transfer those amounts offshore during the year.
Check whether multiple applications can be consolidated.
Where the client falls within the updated SARS guidance, consider whether one annual AIT application can cover the expected transfers for the year.
Obtain the required supporting documents.
Make sure the appointment letter, PAYE confirmation, lease, rental contract or rental statement is available, depending on the type of income.
Calculate the annual estimate.
The estimated annual amount should be supported by the underlying documentation.
Use the updated SARS guidance.
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