South African residents pay tax on their foreign dividends. However, various exemptions apply. In particular, where a resident of South Africa holds at least 20% of the ordinary shares in the declaring company and various other conditions are met, the foreign dividends are exempt from tax in the hands of the South African resident recipient.
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In-house teams who want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues
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