This new development announced by SARS on 27 June 2025, forms part of a broader round of enhancements to taxpayers’ Registration, Amendments and Verification (RAV01) form on SARS eFiling which displays all registered particulars SARS has on file for each taxpayer.

A Long-Anticipated Reinforcement

As of the 2025 tax year, taxpayers who have previously undergone a formal process to cease their South African tax residency with SARS must now declare the “Reinstatement Date of RSA Tax Residency” on the RAV01 form via their eFiling profile with SARS when they return to South Africa.

This new verification step appears to be for purposes of recording the taxpayer’s future tax filing position with the reinstated date on the “Reinstatement Date of RSA Tax Residency” line item on the RAV01-form. Previously, SARS’s verification process was limited to when taxpayers ceased to be South African tax residents only.

This is a significant shift. Until now, SARS had no formal reporting mechanism to track when non-resident taxpayers silently resumed residency under the radar. This created a grey area, with many expats returning and assuming they would be taxed as residents (i.e., on worldwide income and assets) only once SARS became aware of their return. Those days are now over.

By requiring the accurate declaration of a taxpayer’s tax residency status, in line with their travels in and out of South Africa, ensures the Tax Authority does not forfeit taxes due.

The Return Path is Now Monitored

This new reinstatement declaration allows SARS to clearly identify those who are re-entering the South African tax net. More importantly, it gives SARS a gateway to likely revisit and verify:

• An expat’s original date of cessation of tax residency from South Africa and whether this process was valid and completed under SARS verification standards;
• The reasons for return, and whether they align with the taxpayer’s previously declared intentions; and
• The scope of taxable assets and income now brought back into the South African fiscus.

Returning expats should expect SARS to scrutinise their repatriation motives, financial history, and global asset portfolio – especially in cases where obligations for declaring offshore income or capital gains in their local tax returns are involved.

Compliance Risks for the Unprepared

Those who previously ceased tax residency, or worse yet, simply disregarded the formal requirements to regularise their tax affairs after their departure from South Africa, must know the onus is on them as taxpayers to prove their tax residency statuses and ensure their affairs are properly disclosed. Failure to declare a reinstatement, or an inconsistent narrative around the reasons for returning, could lead to:

• Retrospective tax assessments on historic worldwide income by SARS;
• SARS audits or verification requests; and
• Complications in estate planning or trust structuring, due to the reintroduction of global assets into the South African tax net.

Plan Before You Book That One-Way Flight

The recommencement of tax residency is not simply a matter of boarding a flight and moving back home. It is a legally significant step that brings with it serious potential tax implications. For expats with foreign trusts, retirement products, or offshore investments, careful pre-return structuring can mean the difference between strategic reintegration and costly tax surprises.

With the implementation of SARS’ new reinstatement mechanism now in place, expats should be proactive – not reactive.

SARS is clear the onus is on the taxpayers to declare the reinstatement of tax resident status to the revenue collector. This must be done when they are already in South Africa, and the individual taxpayer or their authorised representative must inform SARS by making the declaration.

At this point no supporting documents are required, but tax attorneys believe this is just a first step for SARS in increasing stringent verification processes for expat taxpayers who return to South Africa in future.

Engaging skilled and specialist tax professionals is critical to ensure your return is supported by a credible compliance trail, supported by clear documentation and sound planning.

Returning home should be a joyful experience, not a bureaucratic nightmare. But if SARS suspects a misstep, the tax consequences may follow you long after your bags are unpacked.