Family Office in South Africa: Rules, Costs and Tax in 2026
South Africa has no family office licence or regime: the law firm ENSafrica (August 2026) describes the position as activity-based, so an office that gives financial advice or renders intermediary services as a regular feature of its business needs a financial services provider licence under the FAIS Act, and residents' transfers abroad are subject to the South African Reserve Bank's exchange control. For 2026/27 individuals pay income tax at up to 45%, companies 27% and trusts 45%, and estate duty is 20% on the first ZAR 30 million of an estate's dutiable value and 25% above, after a ZAR 3.5 million deduction. Residence routes include a business visa with at least ZAR 5 million in cash from abroad and permanent residence for financially independent people with a net worth of ZAR 12 million. [1, 2, 3, 4, 5, 6]
Best for: Families with businesses or assets in South Africa who want an office in Johannesburg or Cape Town without a family office licence or wealth minimum (according to ENSafrica), and who accept estate duty on what children inherit, exchange control on moving money offshore and an FSCA licence for any regulated advice or management of client assets.
At a glance
| Licence | No family office licence category (ENSafrica); FAIS licence for advice or client assets reported |
|---|---|
| Minimum wealth | No wealth minimum in the FAIS Act rules read; none for a family office (ENSafrica) reported |
| Who counts as family | No official definition of family found; FAIS covers services to specific clients |
| Serving several families | FSCA licence under the FAIS Act; Category II to manage client assets (ENSafrica) reported |
| Law and courts | Mixed Roman-Dutch, English and customary law; English record; SARB exchange control |
| Substance | No rule found for single family offices; licensed providers need fit and proper, solvency reported |
| Holding vehicles | Companies and trusts; trustees need Letters of Authority from the Master of the High Court |
| Corporate tax | 27% (2026/27); dividends to a South African company exempt from 20% dividends tax |
| Family office tax | No family office regime; trusts 45%; section 7C taxes cheap loans to trusts as donations |
| Personal income tax | 18% to 45%; 45% above ZAR 1,817,000 (ZAR 1,878,600 proposed for 2026/27); gains up to 18% |
| Inheritance tax | Estate duty 20% to ZAR 30 million, 25% above, after ZAR 3.5 million; spouse deductible |
| Wills and succession | Free to make a will from age 16; no forced heirship found; executor fee 3.5% of assets |
| Residence | Business visa: ZAR 5 million cash from abroad; permanent residence: ZAR 12 million net worth |
| Time to set up | No official figure found |
| Official fees | No official figure found |
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Licence and who qualifies
How is a family office licensed in South Africa?
No family office licence, registration or exemption was found in the FAIS Act provisions read (sections 1, 7 and 45) or on the FSCA's licensing page, and no FSCA statement on single family offices was found. Section 7(1) of the FAIS Act requires a licence to act as a financial services provider, a person who 'as a regular feature of the business' furnishes advice or renders an intermediary service, which includes acts for or on behalf of a 'client' (a specific person or group of persons, excluding the general public) with a view to buying, selling, managing or administering a financial product in which the client has invested. Section 45(1)(b)(iv) says the Act does not apply to financial services rendered by the trustee of an inter vivos trust (other than a profit-making business trust built on capital contributed by its beneficiaries) or a person acting on that trustee's behalf, and the list ends, after parents and guardians of minors, with 'unless the financial services are rendered as a regular feature of any such person's business'; no exemption for services to group companies or family members was found, and the registrar may exempt other advisory activity by notice in the Gazette. The law firm ENSafrica (24 August 2026) says South Africa does not formally recognise a family office licence category, that financial advice or intermediary services require FAIS licensing and managing client assets requires a Category II licence, and that governance, tax, succession and similar services ordinarily fall outside FAIS; no official text or law firm source found says whether an office managing only its own family's money is caught. [1, 2, 7, 8]
Reported by the sources named, not confirmed by an official source.
What is the minimum wealth for a family office in South Africa?
No minimum family wealth in the FAIS Act provisions read (sections 1 and 7, which turn on whether advice or intermediary services are a regular feature of a business) or on the FSCA's licensing page, and ENSafrica (August 2026) says South Africa imposes no minimum capital or assets-under-management threshold on a family office as such. Licensed financial services providers must meet solvency requirements, which ENSafrica describes as modest for Category I and more exacting (liquid assets and solvency) for Category II. [1, 2, 8]
Reported by the sources named, not confirmed by an official source.
Who counts as family?
Not found in official sources: no definition of a family, or of whom a single family office may serve, was found in the FAIS Act provisions read or on the FSCA's licensing page. The FAIS Act regulates services to a 'client', defined as a specific person or group of persons, excluding the general public, who is or may become the subject of a financial service, and ENSafrica (August 2026) says the regulatory perimeter is assembled from activity-based statutes rather than a family office licence. [1, 2, 8]
Can one office serve several families?
No dedicated multi-family office licence was found. An office that, as a regular feature of its business, gives financial advice or renders intermediary services for several families needs a financial services provider licence under section 7(1) of the FAIS Act, applied for through the FSCA, whose licensing page lists the forms (including FSP 2 on licence categories) and the fit and proper requirements of Board Notice 194 of 2017. According to ENSafrica (August 2026), managing client assets requires a Category II licence, and Category II providers face more exacting liquid asset and solvency requirements than Category I providers. [1, 2, 8]
Reported by the sources named, not confirmed by an official source.
Law, substance and vehicles
Which law and courts apply?
South Africa has a mixed legal system: the Deputy Minister of Justice said on 28 July 2026 that Roman-Dutch law 'continues to shape South African private law', with English law and customary law also part of it, and section 211 of the Constitution requires courts to apply customary law when it is applicable. The heads of court decided in March 2017 to implement English as the language of record in the superior courts; a litigant may still address the court in another language where practicable, with contemporaneous translation into English. Financial services providers are licensed under the Financial Advisory and Intermediary Services Act (FAIS Act) by the Financial Sector Conduct Authority (FSCA), deceased estates and trustees come under the Master of the High Court, and exchange control is applied by authorised dealers under the South African Reserve Bank's Currency and Exchanges Manual: residents aged 18 or over may send ZAR 2 million per calendar year abroad under the single discretionary allowance (from 8 April 2026, up from ZAR 1 million) and up to ZAR 10 million a year under the foreign capital allowance with SARS approval (AIT) and a tax compliance check, larger amounts need approval from the Reserve Bank's Financial Surveillance Department, and people who cease to be tax resident can move assets abroad once SARS confirms their tax compliance status, with stricter SARS verification above ZAR 10 million a year. [2, 3, 8, 9, 10, 11, 12, 13, 14, 15]
What substance is required?
No office, staff or local spending rule for a single family office was found in the FAIS Act provisions read or on the FSCA's licensing page, and ENSafrica (August 2026) says there is no minimum capital or assets-under-management threshold for a family office as such. A licensed financial services provider must meet the fit and proper requirements of Board Notice 194 of 2017 (FSCA) and, according to ENSafrica, solvency requirements that are stricter for Category II than for Category I. [1, 2, 8]
Reported by the sources named, not confirmed by an official source.
Which holding vehicles are available?
Companies and trusts are the vehicles found in the official sources opened. A trust is formed when a founder places cash or other assets under the control of trustees; under section 6(1) of the Trust Property Control Act 57 of 1988 nobody may act as trustee without authorisation, and the Master of the High Court issues Letters of Authority to the trustees (SARS guide, September 2026). Exchange control allows an individual's approved investment abroad above the ZAR 10 million foreign capital allowance to be made through a foreign domiciled and registered trust. [3, 12]
Tax
What is the corporate tax rate?
Companies pay 27% income tax for years of assessment ending from 1 April 2026 to 31 March 2027 (unchanged in Budget 2026), with a maximum effective rate of 21.6% on capital gains; companies in approved Special Economic Zones may qualify for 15%. Dividends tax (20%) does not apply where the beneficial owner of the dividend is a South African company, so dividends from South African companies to a South African family holding company are exempt from it, and donations between companies in a South African group are exempt from donations tax. The income tax treatment of foreign dividends and share gains received by companies was not checked. [4, 16]
Are there tax incentives for family offices?
No tax regime for family offices or family investment companies was found in SARS's Budget 2026 publications. Trusts other than special trusts pay a flat 45% income tax and have a maximum effective rate of 36% on capital gains; income that vests in a beneficiary in the same year is treated as the beneficiary's (section 25B), a capital gain vested in a resident beneficiary is taxed in that beneficiary's hands (paragraph 80(1) of the Eighth Schedule), and section 7 can tax trust income in the hands of the person who made a donation. Since 1 March 2017, section 7C treats the interest forgone on an interest-free or low-interest loan by a connected person to a trust (and, in some cases, to a company whose shares a trust holds) as a donation subject to donations tax, calculated at the official rate. [4, 16, 17, 18]
Is there personal income tax?
Residents pay income tax at rates from 18% to 45%. Budget 2026 (25 February 2026) proposed raising the brackets by 3.4% for 2026/27 (1 March 2026 to 28 February 2027), with the 45% rate on taxable income above ZAR 1,878,600 and a tax threshold of ZAR 99,000 for people under 65; a draft 2026 Rates Bill was published for comment in June 2026, but SARS's list of bills (checked 20 October 2026) shows no 2026 Rates Bill introduced in Parliament, and the latest enacted table, in the Rates and Monetary Amounts and Amendment of Revenue Laws Act 3 of 2026 (assented 31 March 2026), applies to years of assessment from 1 March 2025 with the 45% rate above ZAR 1,817,000. Interest up to ZAR 23,800 a year (ZAR 34,500 from age 65) is exempt, dividends from South African companies bear a final 20% dividends tax, most foreign dividends received by individuals holding less than 10% are taxed at a maximum effective rate of 20%, and individuals' capital gains have a maximum effective rate of 18%; Budget 2026 proposed raising the annual exclusion from ZAR 40,000 to ZAR 50,000 and the primary residence exclusion from ZAR 2 million to ZAR 3 million. No special regime for new residents was found in the sources opened; the residence basis of income tax and the foreign employment income exemption were not confirmed in an official source opened. [4, 16, 19, 20, 21]
Is there inheritance or estate tax?
Estate duty applies to the property of residents and the South African property of non-residents: 20% on the first ZAR 30 million of an estate's dutiable value and 25% above, after a basic deduction of ZAR 3.5 million (section 4A) and deductions for liabilities, bequests to public benefit organisations and property accruing to a surviving spouse (section 4(q)); where a spouse died first, the deduction can reach ZAR 7 million less any amount the first estate used, and the deductions SARS lists do not include bequests to children. Donations tax is 20% on cumulative donations since 1 March 2018 up to ZAR 30 million and 25% above; a natural person's first ZAR 100,000 a year is exempt (Budget 2026 proposed ZAR 150,000, not yet enacted), as are gifts between spouses where the recipient is a tax resident and between companies in a South African group. At death assets are deemed disposed of for capital gains tax, with no tax on property inherited by a surviving spouse, and the capital gains exclusion in the year of death is ZAR 300,000 (Budget 2026 proposed ZAR 440,000, not yet enacted). [4, 16, 19, 20, 22]
Succession and residence
How do wills and succession work?
The Master of the High Court says any person aged 16 or over is free to make a will to decide how his or her estate devolves, and a person may arrange by will for the estate to be distributed under customary law; no forced heirship share was found in the official sources opened. Without a valid will the Intestate Succession Act applies: a spouse inherits the greater of ZAR 250,000 or a child's share and the children the balance. An estate is reported within 14 days to the Master's office where the deceased normally lived, an executor (for estates of ZAR 250,000 or less, a Master's representative) lodges the liquidation and distribution account within six months of appointment, and the executor's fee is 3.5% of the gross value of assets plus 6% of income collected after death (at least ZAR 350). [11, 22, 23]
Can the family get residence?
The main investor route is the business visa: the applicant must invest at least ZAR 5 million in cash originating from outside South Africa (or cash plus new machinery or equipment) in a new or existing business, obtain a recommendation from the Department of Trade and Industry and employ South African citizens or permanent residents as at least 60% of staff within 12 months; it is issued for up to three years at a time, and the Director-General may reduce or waive the capital for businesses in the national interest. In a reply to Parliament on 11 June 2026 the Minister of Home Affairs said 33 business visas were approved and 57 rejected for not meeting the capital threshold in 2025/26, and that no waivers of the ZAR 5 million had been granted since waiver applications moved online in October 2025. Permanent residence for financially independent people requires a net worth of ZAR 12 million and a payment of ZAR 120,000 on approval, and the application can cover a spouse and dependent children; a remote work visa (from 9 October 2024) is for people working for a foreign employer with a gross salary of at least ZAR 650,796 a year, and the amounts for the retired person visa are set by Gazette notice (not found). [5, 6, 24, 25, 26, 27]
Time and fees
How long does set-up take?
Not found in official sources.
What are the official fees?
Not found in official sources: company registration fees were not checked, and the FSCA's licensing page lists the FAIS licence application forms but no fee. The only official amount found is the ZAR 120,000 payment on approval of permanent residence for financially independent people (see residency). [6, 8]
Pros and cons
Pros
- There is no family office licence category and no minimum capital or assets-under-management threshold for a family office as such, according to ENSafrica, and governance, tax and succession services ordinarily fall outside FAIS licensing.
- Anyone aged 16 or over is free to make a will, including one applying customary law, and property passing to a surviving spouse is deductible for estate duty and free of capital gains tax at death.
- Investor routes are open: a business visa from ZAR 5 million in cash from abroad, and permanent residence for financially independent people with a net worth of ZAR 12 million plus a ZAR 120,000 payment.
Cons
- Estate duty of 20% on the first ZAR 30 million and 25% above applies after a ZAR 3.5 million deduction, with no deduction for bequests to children among those SARS lists, and assets are deemed disposed of for capital gains tax at death.
- Exchange control limits transfers abroad to ZAR 2 million a year under the single discretionary allowance and ZAR 10 million under the foreign capital allowance with SARS approval; larger amounts need Financial Surveillance Department approval.
- An office that gives financial advice or manages client assets as a regular feature of its business needs an FSCA licence, no official exemption for a single family office was found, and trusts pay a flat 45% income tax.
