Non-residents may invest in South African (SA) property by direct offshore ownership of the property, or via resident companies, close corporations, trusts, share block schemes or unit trusts.
In the case of direct offshore ownership, a non-resident company seeking to acquire SA real property is required to set up a SA branch (or, as termed in the South African Companies Act, an ‘external company’) if it engages in business activities or is party to an employment contract in SA. There is no similar requirement for non-resident individuals.
There are few restrictions on non-residents making property investments. Dividends, rent and interest are, generally speaking, freely remittable. Certain aspects of the making and the repatriation of loans by non-residents to residents, and the payment of interest thereon, require the prior approval of the South African Reserve Bank.
Profits distributed by way of dividend are subject to a 15% dividend withholding tax (WHT) subject to any relief under applicable double tax treaties.
South Africa also imposes local borrowing restrictions in certain cases.
Source : PWC