Estate Administration Tools
Access our complete suite of free resources for South African deceased estates.
Offshore Assets, Platforms & Situs Tax
Key Takeaways for Offshore Investors
- Worldwide Taxation: If you are a resident of SA, SARS charges Estate Duty on your global wealth, including foreign stocks.
- The Platform Trap: Buying US stocks directly on platforms like EasyEquities USD or Webull exposes your estate to up to 40% US Situs Tax.
- The Fix: Shifting assets into ZAR-denominated feeder funds or offshore endowment wrappers legally bypasses this foreign tax.
South Africans are increasingly diversifying their wealth into global markets. However, the exact platform and legal structure you use to buy offshore assets determines whether your family inherits the wealth, or whether a foreign government takes up to 40% of it.
The Danger of Situs Tax (US & UK)
While SARS taxes you based on residency, countries like the United States and the United Kingdom tax based on Situs (the physical or legal location of the asset). If you die owning shares "situated" in their country, they demand an inheritance tax before your South African executor can access the funds.
- United States: Non-US citizens only receive a tiny $60,000 exemption. Any US-situated assets above $60,000 are subject to US Estate Tax at sliding scale rates up to 40%.
- United Kingdom: The UK grants a £325,000 "nil-rate band", but anything above that is subjected to a flat 40% Inheritance Tax.
Are You Exposed? Common SA Platforms
Many South Africans trigger this tax accidentally by using the wrong type of investment account. Here is how popular platforms are treated upon death:
Holding direct US shares triggers US Situs Tax on amounts over $60k.
Depends on the domicile of the ETF, but direct US stocks are fully exposed.
If holding US/UK direct shares, you are liable for foreign tax upon death.
ZAR feeder funds (e.g., Sygnia, Allan Gray) bypass Situs completely.
âš–ï¸ Situs Tax & Foreign Probate Quick-Check
Select the country where your offshore shares or bank accounts are legally held to see if your South African Will is sufficient, or if foreign probate will trap your assets.
🌠Interactive Situs Tax Visualiser
Input your foreign portfolio value to see how much of your wealth could be lost to foreign inheritance taxes before it even reaches South Africa.
You can legally bypass Situs Tax and Foreign Probate entirely by changing how you hold the assets. When you use a local "Offshore Endowment Wrapper" (offered by life companies like Allan Gray, Glacier, or Momentum), you no longer own the foreign shares directly. You own a South African policy that mirrors the offshore investment. Because the policy is issued in SA, it legally shifts the Situs back home. Your SA Executor deals with it seamlessly, paying only standard SA Estate Duty.
Include Global Assets in Your Calculation
When using our primary Estate Duty calculator, remember to convert the value of all your offshore accounts and portfolios into ZAR and include them in your Gross Assets to get an accurate projection.
Go to the Estate Duty Calculator →