Authors: Rizquah Mahomed and Mbuyisile N.
For many South Africans living and working abroad, there is a common assumption that leaving the country means leaving the South African tax net.
Increasingly, SARS is making it clear that this is not necessarily the case.
The cessation of South African tax residency has become one of the most scrutinised areas of cross-border taxation, with SARS adopting a far more technical, evidence-driven approach when assessing non-residency claims. What was once viewed by many taxpayers as a largely administrative process has evolved into a substantive tax determination requiring careful legal analysis and robust supporting evidence.
This shift is not entirely unexpected. Over the past few years, SARS has consistently signalled its intention to strengthen compliance and improve visibility over internationally mobile taxpayers. The 2026 filing season provides further evidence of this focus, with enhanced residency-related disclosures and guidance incorporated into the ITR12 process. Taxpayers are now required to provide more detailed information regarding changes in residency status, and the information supplied may influence whether SARS presents a resident or non-resident return for completion.
Importantly, the process for declaring a change in tax residency has not materially changed. Taxpayers must still update their status through the RAV01 form on eFiling, often followed by a verification process and requests for supporting documentation. What appears to have changed, however, is the depth of scrutiny being applied to the underlying facts.
