As a first step, it is important to determine if you are tax resident of South Africa, as laid out by the two tax residency tests:

Click here to download the Ordinarily resident test.
Click here to download the Physical presence test.

If you are determined to be tax resident of SA, you are obligated to declare your past and present foreign and local earnings made aboard the vessel and apply for exemption where possible. It is important to note the two tax exemptions that can be applied on foreign employment income for those working on vessels. You can obtain tax relief on your foreign earnings if either exemption can be claimed. Click on the plus sign to read more.

Exemption 1: Section 10(1)(o)(i) of the Income Tax Act

“10(1) There shall be exempt from normal tax—

(o) any form of remuneration—

(i) as defined in paragraph 1 of the Fourth Schedule, derived by any person as an officer or crew member of a ship engaged—

(aa) in the international transportation for reward of passengers or goods; or

(bb) in the prospecting, exploration or mining (including surveys and other work of a similar nature) for, or production of, any minerals (including natural oils) from the seabed outside the Republic, where such officer or crew member is employed on board such ship solely for purposes of the “passage” of such ship, as defined in the Marine Traffic Act, 1981 (Act No. 2 of 1981), if such person was outside the Republic for a period or periods exceeding 183 full days in aggregate during the year of assessment.”

 A quick look at the “section 10(1)(o)(i) exemption” requirements:

  • Income received must be for foreign employment aboard the vessel;
  • The vessel must be either carrying passengers/goods for reward;
  • The taxpayer must be part of the safe passage or navigation of the vessel; and:
  • The taxpayer must be outside of SA for more than 183 days for the year of assessment.

Exemption 2: Section 10(1)(o)(ii) of the Income Tax Act

 “10(1) There shall be exempt from normal tax—

(o) any form of remuneration—

(ii) received by or accrued to any employee during any year of assessment by way of any salary, leave pay, wage, overtime pay, bonus, gratuity, commission, fee, emolument or allowance, including any amount referred to in paragraph (i) of the definition of gross income in section 1 or an amount referred to in section 8, 8B or 8C in respect of services rendered outside the Republic by that employee for or on behalf of any employer, if that employee was outside the Republic

 (aa) for a period or periods exceeding 183 full days in aggregate during any period of 12 months; and

(bb) for a continuous period exceeding 60 full days during that period of 12 months,

and those services were rendered during that period or periods”


A quick look at the “section 10(1)(o)(ii) exemption” requirements:

  • Income received must be derived through foreign employment.
  • The taxpayer must be outside of SA for more than 183 days for the year of assessment.
  • The taxpayer must be outside of SA for a continuous period exceeding 60 days for that year of assessment.
  • Kindly note the exemptions has been amended to exempt only the first R1 million as of March 2020.

Should one not have any assets, in SA, nor be a tax resident, it will not be necessary to register for tax, however it will still be advisable to ensure your non-residency is formalised with the authorities. This is extremely important to mitigate risk with the amended expatriate tax law taking effect 1 March 2020.

Take the First Step to Secure Your Home Port

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