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🇿🇦 Ceasing South African Tax Residency from Ireland: The Three Routes, the Exit Tax and Your Retirement Annuity
8,250 South African citizens were living in Ireland at the 2022 census, the second-largest African community here (CSO, table F5065), and many more South African-born people hold Irish or other passports. Most of them, sooner or later, face the same question: am I still a SARS taxpayer, and should I formally stop being one? This guide covers the South African mechanics as SARS and South African advisers describe them, and the Irish side we deal with every day. The South African steps themselves are for a registered South African tax practitioner.
- South African tax residence ends as a matter of fact, not by a form: you stop being ordinarily resident, pass the 330-day test, or the treaty makes you resident only in Ireland.
- SARS still has to be told, through a RAV01 update and a declaration with evidence, including an Irish Letter of Residence on the treaty route.
- Ceasing triggers a deemed disposal of your worldwide assets except South African property and retirement funds (section 9H), taxed at no more than 18% of the gain.
The 330-day test applies if you were resident only under the physical presence test: 330 continuous full days outside South Africa. Retirement annuities can be paid out in full after three unbroken years of non-residence.
Do you have to cease South African tax residency?
- It isn't really a choice: if one of the three tests ends your residence, you're non-resident from that date whether or not you tell SARS.
- If none does, you're still resident and taxed on worldwide income, with the R1.25 million foreign employment income exemption as the main relief.
- You choose when to tell SARS and, where the facts allow, when to take the steps that end your residence, such as moving your family or giving up a home there.
The date those facts fix decides when the exit tax is measured and when your retirement annuity clock starts.
- While you're still SARS resident, South Africa taxes your worldwide income. Irish salary is exempt up to R1.25 million if you spend more than 183 full days outside South Africa in a 12-month period, including a continuous period of more than 60 full days (SARS); Irish interest, dividends and gains aren't, and you keep filing South African returns. Our South African workers guide covers that position.
- Once you're non-resident, South Africa taxes only South African-source income: rent and gains on South African property, South African dividends and interest, and South African retirement fund payments.
- Ireland doesn't care which you choose. If you're Irish resident (183 days in a tax year, or 280 over this year and last with more than 30 this year), Ireland taxes your salary the same way either way, and the Ireland–South Africa treaty decides who gets the first claim on everything else.
What are the three ways to cease South African tax residency?
- SARS recognises three routes, and the first is that you're no longer ordinarily resident: South Africa is no longer your real home (SARS).
- Or you were resident only under the physical presence test and you've been outside South Africa for 330 continuous full days.
- Or you're resident in another country under a tax treaty; each route has its own date and its own evidence.
| Route | When residence ends | Evidence SARS asks for, on top of the standard declaration |
|---|---|---|
| No longer ordinarily resident | The day you ceased to reside in South Africa, judged on your intention and objective facts | Visa or permit details, proof of permanent residence abroad if any, a foreign tax residence certificate if available, and details of South African property, business interests, family, social ties, belongings and return visits |
| Physical presence test: 330 continuous full days outside South Africa | The day you left South Africa | The standard documents only |
| Treaty: resident only in Ireland under Article 4 | When the treaty tie-breaker first puts you in Ireland | A certificate of tax residence from Revenue (the Letter of Residence) |
- The standard documents for every route: a signed declaration stating the basis for cessation, a motivation letter setting out the facts in detail, and copies of your passport or travel record with all entry and exit stamps.
- The treaty route is the one most people in Ireland use, because a home, a job and family here usually settle the Article 4 tie-breaker in Ireland's favour. It's applied year by year, so a year in which you kept a home available to you in South Africa can be harder to argue.
- Financial emigration is no longer a route. The old exchange-control process ended on 1 March 2021 and was separated from tax residence; anyone who emigrated financially before then but never ceased tax residence now goes through the SARS process like everyone else.
How do you tell SARS, and what does Ireland need to provide?
- On eFiling, update the RAV01 with your cessation date, which SARS treats as the day you became non-resident.
- Then submit the declaration and supporting documents through eFiling or SOQS.
- On the treaty route, the Irish piece is a Letter of Residence, requested in myAccount and issued once Revenue is satisfied you're Irish resident for the year.
- Settle your Irish residence first. Count your days for each year since you moved, using our tax residence check. The cessation date you give SARS should match a year Revenue will confirm.
- Request a Letter of Residence in myAccount for each relevant year (Revenue manual 35-01-05). It supports your position; SARS still reaches its own conclusion under South African law.
- Update the RAV01 on eFiling with the cessation date, then file the declaration with the motivation letter, travel record and route-specific evidence. SARS can decline a declaration that doesn't meet the criteria.
- File the South African return for the year you cease. South African advisers describe that year as split: worldwide income up to the day before cessation, South African income only after it, with the exit tax in the resident part.
- Keep a copy of what you filed and any confirmation SARS issues; South African retirement funds and banks will ask for proof of non-residence later.
What does ceasing cost? The section 9H exit tax
- Section 9H of the Income Tax Act treats you as having sold your worldwide assets at market value the day before residence ends.
- South African immovable property, retirement fund interests and most personal-use assets are left out.
- After a R50,000 annual exclusion, 40% of the gain is included in income: at most 18% of the gain at the 45% top rate (PwC, reviewed May 2026).
| Asset | Caught by the exit tax? | What happens instead |
|---|---|---|
| JSE shares, unit trusts, offshore investments, crypto | Yes, at market value the day before cessation | Gain since you bought them taxed in the year you cease |
| A house or flat in South Africa | No | Stays in the South African net: taxed when you actually sell, with 7.5% of the whole price withheld for a non-resident seller as an advance on the tax if the price is above R2 million (PwC; SARS) |
| Retirement annuity, pension or provident fund | No | Taxed when you withdraw; a 2021 proposal for a separate retirement-fund exit charge was withdrawn and isn't law |
| Assets of a South African branch or business (a permanent establishment) | No | Stays in the South African net |
| Cash and personal-use assets | Generally no | Nothing to tax on cessation |
- No matching step-up in Ireland. Ireland doesn't reset your base cost when South Africa does. If you later sell the same shares while Irish resident, Irish CGT (31% for disposals from 7 October 2026) is worked from what you originally paid, on the whole gain if you're Irish-domiciled or on the gain you bring into Ireland if you're not. Whether the South African exit tax can be credited against that later Irish CGT isn't straightforward, because the two taxes arise in different years: get advice on both sides before you choose your cessation date.
- Timing is the main lever. The exit tax is measured on the day before your cessation date, so a portfolio that has fallen in value, or a cessation date in your first Irish year rather than five years later, changes the bill. Your cessation date isn't free to choose, though: it follows the facts of the route you use.
- Spouses. South African advisers report that from 25 February 2026 the exemption for donations between spouses no longer applies where the receiving spouse is non-resident (Tax Consulting SA). If one of you ceases and the other doesn't, gifts from the resident spouse to the non-resident one can attract South African donations tax (20%, or 25% above R30 million).
Worked example: a share portfolio, a flat in Durban and an RA
- Thandi, in Dublin since 2024, ceases South African residence under the treaty from 1 June 2026, with a R600,000 gain on her JSE portfolio the day before.
- After the R50,000 exclusion, 40% of R550,000, R220,000, is added to her income: R99,000 at the 45% top rate, the 18% maximum.
- It's less if her other South African income for the period is low, and her Durban flat and her RA aren't caught.
Starting data (assumptions): Thandi moved to Dublin for a job in March 2024 and has been Irish resident for 2024, 2025 and 2026. Until 31 May 2026 her husband and children lived in her flat in Durban, so she had a permanent home in both countries and her centre of vital interests stayed in South Africa. On 1 June 2026 they joined her in a home she rents in Dublin and the Durban flat was let to tenants; from that day she has no home available to her in South Africa, the treaty makes her resident only in Ireland, and she uses 1 June 2026 as her cessation date on the RAV01. Had her family moved with her in 2024, the tie-breaker would have put her in Ireland then, and the exit tax would have been measured on the day before she left. On 31 May 2026 her JSE share portfolio is worth R1,400,000 against a base cost of R800,000. She also has a retirement annuity worth R900,000. She has made no other capital gains between 1 March and 31 May 2026, the resident part of the 2027 South African tax year. To show the ceiling, we assume her other South African taxable income for the resident part of the year already reaches the 45% bracket, so the whole included gain is taxed at 45%. On her real facts it may not: her Irish salary for March to May falls within the R1.25 million foreign employment income exemption, and if the R220,000 were her only taxable income for the period it would be taxed at 18%, under R40,000 before the primary rebate.
| Calculation | Amount | |
|---|---|---|
| Deemed proceeds less base cost (shares) | R1,400,000 − R800,000 | R600,000 |
| Less annual exclusion | −R50,000 | |
| Net capital gain | R550,000 | |
| Included in taxable income at 40% | R550,000 × 40% | R220,000 |
| Exit tax at the 45% marginal rate | R220,000 × 45% (= 18% of R550,000) | R99,000 |
| Durban flat | Excluded: taxed only when sold | R0 now |
| Retirement annuity | Excluded: taxed only when withdrawn | R0 now |
On the Irish side nothing happens on 1 June 2026: there's no Irish disposal. If Thandi sells the shares in 2028 and brings the proceeds to Dublin, Irish CGT is due on the gain from her original R800,000 cost converted at the rate when she bought, not from the R1,400,000 South Africa used. She should look at that before choosing to keep or sell the portfolio, and from June 2026 the rent from the Durban flat goes on her Irish return each year: in full if she's Irish-domiciled, or when brought in if she's not, with credit for the South African tax under the treaty.
What happens to your retirement annuity?
- Since 1 March 2021, you can withdraw a South African RA in full before 55 only after three unbroken years of non-residence, counted from your cessation date.
- On the ordinary-residence and treaty routes, that date can be later than the day you left.
- Since the two-pot system began on 1 September 2024, the savings component can be drawn once per tax year (minimum R2,000) wherever you live.
The retirement and vested components stay locked until the three years are up or you reach retirement age.
- The three-year clock starts on the cessation date you record with SARS, so a cessation backdated to the facts can start it earlier than a late notification suggests. Funds generally ask for SARS confirmation of non-residence and a tax directive before paying, and the withdrawal is taxed under the pre-retirement withdrawal lump sum tables (FinGlobal, August 2026).
- The two pots. Contributions from 1 September 2024 are split one third savings, two thirds retirement; everything before then is the vested component under the old rules (FinGlobal). Savings-pot withdrawals are taxed in South Africa at your marginal rate.
- Irish tax on an RA payout. A South African retirement payment received while you're Irish resident can be within Irish tax too, under the treaty's pensions article with credit for the South African tax; how Ireland treats a foreign retirement lump sum is technical, and since October 2026 Revenue says a fund that allows access for non-retirement purposes isn't a foreign pension arrangement. Our guide to withdrawing a South African RA from Ireland works through the SARS tables, the treaty and the Irish side with an example.
- Moving it out. Transferring the proceeds abroad above the single discretionary allowance needs an Approval International Transfer (below).
How do you move money out of South Africa now?
- Up to R2 million a calendar year under the single discretionary allowance, without a tax compliance PIN, after the Reserve Bank's April 2026 changes.
- Above that, use an Approval International Transfer (AIT) on eFiling, which gives you a Tax Compliance Status PIN for your bank (SARS).
- AIT covers both residents sending funds abroad and people who have ceased tax residence.
- Single discretionary allowance: raised from R1 million to R2 million a year by the exchange control circulars of 8 April 2026 (Moonstone). Check current limits with your bank.
- AIT: apply through the Tax Status menu on eFiling; SARS checks your compliance and asks for supporting documents about the source of the funds. Your compliance status isn't fixed, so apply close to the transfer.
- On the Irish side, bringing the money in doesn't create Irish tax by itself: savings and capital you had before you became Irish resident aren't income. But if it's rent, dividends or sale proceeds that Ireland taxes on the remittance basis, the transfer is the taxable event; see the remittance basis guide.
What Revenue actually asks for
- Revenue doesn't need to know that you've ceased South African residence.
- It needs your Irish return for each year, with any South African income or gains Ireland taxes declared and the South African tax claimed as a treaty credit.
- If you claim the remittance basis, add a statement that you're not Irish-domiciled.
- Letter of Residence from myAccount for each year SARS asks about.
- South African rent, dividends, interest and gains that Ireland taxes (all of it if you're Irish-domiciled, what you brought in if you're not) on Form 12 if taxable non-PAYE income is €5,000 or less and gross non-PAYE income €30,000 or less, otherwise Form 11.
- The treaty credit for South African tax on the same income, with the South African assessment or withholding statement as proof; the exit tax on unsold shares isn't Irish income, so there's nothing to declare in Ireland for it in the year you cease.
- Your Irish credits and reliefs for every open year; 2022 closes on 31 December 2026.
Where do you start?
Work out which year the treaty first made you resident only in Ireland, and what your South African investments were worth the day before. Those two facts give you the cessation date and the exit tax; then take them to a South African tax practitioner, and keep the Irish side, including what happens when you later sell, in the same plan.
Related reading
- Tax for South African workers in Ireland: refunds and the SARS question
- Ireland–South Africa tax treaty: who taxes what
- Withdrawing a South African retirement annuity from Ireland
- The remittance basis for non-domiciled residents
- Foreign rental income: a house back home and Irish tax
- Capital gains tax in Ireland
- Tax guides by nationality
Questions we get asked
How do I cease South African tax residency if I live in Ireland?
Work out which route ends your residence (no longer ordinarily resident, 330 continuous full days outside South Africa, or the treaty tie-breaker), then update the RAV01 on eFiling with the cessation date and submit SARS's declaration with a motivation letter, your travel record and the route's evidence. On the treaty route that includes a Letter of Residence from Revenue.
What does it cost to cease tax residency in South Africa?
The main cost is the section 9H exit tax: a deemed disposal of your worldwide assets at market value the day before residence ends, excluding South African property and retirement funds, taxed at no more than 18% of the gain after the R50,000 annual exclusion. Practitioner fees come on top.
Is SARS financial emigration still possible?
No. Financial emigration through the Reserve Bank ended on 1 March 2021. Tax residence now ends through SARS's own cessation process, and large transfers abroad go through an Approval International Transfer.
When can I withdraw my retirement annuity after leaving South Africa?
In full before 55, after three unbroken years of non-residence counted from your cessation date. Under the two-pot system, the savings component can be drawn once a year (minimum R2,000) wherever you live.
Does ceasing SA residency change my Irish tax?
Not your Irish salary. It can change what South Africa taxes you on, and when you later sell investments Irish CGT is worked from your original cost, not from the value South Africa used for the exit tax.