22.2 PART 1 – NON RESIDENT COMPANY
If a non-resident company becomes a resident company in RSA (this could be a foreign company becoming domesticated) on or after the 1st of January 2011 it’s contributed tax capital will be calculated as follows;
The market value of all shares on the day before
the company becomes resident RX
Plus the consideration for new shares issued RY
Total CTC RX+RY=CTC
All the reserves realised and unrealised of the company immediately before it becomes resident in South Africa is effectively the starting point for CTC for income tax purposes and any repayment of these reserves is not a dividend.
A non-resident company can become a tax resident by moving its place of effective management to South Africa. This happens when one or more Directors manage the company from premises in South Africa.