Zero-rating for non-residents

In an Interpretation Note published on 27 March 2015, SARS has provided further clarity regarding the test for zero-rating of services supplied to non-residents.  The supply of services to non-residents generally qualifies for zero-rating.  However, it is necessary to test whether any of the three exclusions will apply before confirming that the services supplied will be zero-rated.  The services must not be supplied:

  • In connection with land in South Africa.
  • In connection with movable property situated in South Africa (subject to certain exclusions).
  • To a non-resident in South Africa at the time that the services are rendered.

It is therefore important to test the specific exclusions against the particular facts before assuming the general position of zero-rating services supplied to non-residents.

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