South Africa税务居民规则:183天判定标准
183天门槛
South Africa的 183 天规则如何运作
South Africa counts 183 days in any 12 month period, plus more than 91 days in the current year and 915 days over five years.
滚动 12 个月窗口. 这意味着计算从任一日期往回看,而非仅看日历年度边界。滚动窗口更难手动追踪,因为数字每天都在变化。
如果超过 183 天,South Africa可能会将你的全球收入作为税务居民征税。具体后果取决于你的个人情况、适用的税收协定及收入类型。
天数怎么计算
South Africa runs two residency tests side by side. The "ordinarily resident" test is principles based and asks where your real home is, where you intend to return after travel. Running alongside it is a mechanical "physical presence" test that catches you when you spend more than 91 days in the current year of assessment, more than 91 days in each of the preceding five years, and at least 915 days in total across those five years.
什么算作一天
Any day with physical presence in South Africa for any part of it counts. The tax year (the year of assessment in SARS terminology) runs from 1 March to the last day of February.
天数之外的判定标准
The ordinarily resident test can pull you into residency well below the mechanical 91/183/915 day thresholds. Owning a South African home you regularly return to, with family or business ties to back it up, will usually establish ordinary residence on its own.
特殊税务制度
The foreign employment income exemption shelters the first ZAR 1.25 million of foreign employment income from South African tax each year, provided you spent more than 183 days abroad during the year of assessment, including a continuous spell of at least 60 days.
税收协定
South Africa has more than 80 tax treaties, all built on OECD style tiebreakers. A treaty determination overrides the domestic physical presence test if the OECD hierarchy points to another country.
常见问题
What is the difference between ordinarily resident and physical presence?
Ordinarily resident is the principles based test, asking where your real home actually is. Physical presence is the mechanical version, built on day counts across six years of assessment. Either route is enough to make you South African tax resident.
How does the foreign employment income exemption work?
When you spend more than 183 days outside South Africa during the year and include a continuous 60 day spell abroad, the first ZAR 1.25 million of your foreign employment income is exempt from South African tax. SARS has held the cap at that level for several years.
When does the South African tax year run?
From 1 March to the last day of February. Day counts under the physical presence test use that window, not the calendar year.
官方来源: https://www.sars.gov.za/individuals/tax-during-all-life-stages-and-events/tax-and-emigration/