FOREIGN-REGISTERED COMPANIES IN SOUTH AFRICA

 FOREIGN-REGISTERED COMPANIES IN SOUTH AFRICA

Companies registered outside South Africa may conduct business in South Africa in two ways.  Firstly, the company can register a South African subsidiary.  Alternatively, the company can register as an “External Company” in terms of section 23 of the Companies Act. Even none of the incorporators have a South African visa.

REGISTERING A COMPANY IN SOUTH AFRICA

The incorporators of external companies do not need South African visas to register the external company.  When is a company deemed to be “conducting business” in South Africa?  The Companies Act stipulates that only when the company is a party to an employment contract or when it has acted in such a way as to appear that it will be continually operating in South Africa.

ACTIONS TO TAKE PRIOR TO CONDUCTING BUSINESS IN SOUTH AFRICA

The following actions must be done to justify recognition as an external company “conducting business” in South Africa:

1.       Conducting a meeting of the shareholders or board of the foreign company on South African soil, or otherwise conducting any of the company’s internal affairs within the Republic;

2.       Establishing or maintaining a bank account in the Republic;

3.       Establishing or maintaining offices or agencies within the Republic for the transfer, exchange, or registration of the foreign company’s own securities;

4.       Creating or acquiring any debts within the Republic, or any mortgages or security interests in any property within the Republic;

5.       Securing or collecting any debt, or enforcing any mortgage or security interest within the Republic; or

6.       Acquiring any interest in any property within the Republic.

CONSIDERATIONS WHEN EXPANDING BUSINESS INTO SOUTH AFRICA

Foreign nationals are advised to seek professional advice when considering external companies, as South Africa does not have dual taxation treaties with all other countries.  If the country of origin of the foreign entity is not a party to a dual taxation treaty with South Africa, then the external company may end up paying income tax twice on the same earnings, which will usually be fatal to the entity’s prospects of success.

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