Africa Common Law
Founders building a Pan African operating HQ, South Africa
South Africa's HQ Company Regime exempts qualifying foreign dividends, capital gains and interest for groups managing African subsidiaries. 80 DTAs cover the UK, USA, Germany, Mauritius and India, with English admin and a common law system.
HQ Company Regime80 DTAsCommon law
Start setup {placement} 4 min · no card required
Corp tax
27%
Fastest setup
2 weeks
Tax treaties
80
Region
Africa
What you'll need
- No resident director required
- Local registered office required
- Economic-substance test applies
- Minimum capital: ZAR 1
- Administrative language: English
- Legal system: Common law
Tax and treaty profile
- Corporate tax 27%
- Tax treaties 80
- VAT rate 15%
- Withholding on dividends 20%
Key treaty partners
UKUSAGermanyNetherlandsMauritiusIndia
Banking and payments
- Banking is straightforward
- Stripe supported
- Wise supported
- Crypto banking available
- EMI license framework available
Considerations
If tax efficiency or capital mobility is the binding constraint
South Africa runs a 27% CIT, 20% dividends withholding, exchange controls under SARB and remains on the FATF grey list (since 2023). For lower tax and free capital flows:
FATF grey list27% CITSARB exchange controls