The South African Minister of Finance announced a Special Voluntary Disclosure Programme (SVDP) in his Budget speech on 24 February 2016. The motivation behind this was to afford taxpayers with a final opportunity to regularise their offshore tax position prior to SARS being made aware of South African tax residents’ offshore interests via the international automatic exchange of information under the Common Reporting Standard of the Organisation for Economic Co-operation and Development (OECD). The SVDP bill, which was released on 24 February 2016, has throughout the course of last year undergone a number of substantial changes, following intensive feedback from interested groups during the public hearing process, and was finally promulgated in January this year. Even though many of those affected are still coming to terms with the scope of the CRS, which leaves virtually no other option other than to regularise their offshore position, the real question for most is whether or not t...

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