The window period for South African residents to regularise
their unauthorised foreign assets under the Special Voluntary
Disclosure Programme ("SVDP") closes on
31 August 2017. The current SVDP is the latest in a series of such
opportunities offered by the Financial Surveillance Department of
the South African Reserve Bank ("SARB"),
beginning with the 2003 exchange control amnesty.
It is worth considering the SVDP in the context of both the
current era of financial transparency and the increased political
will to prosecute "illicit financial flows". To some
extent, transparency is being driven by standards targeting money
laundering and terrorist financing. In a tax context, however, the
instrument likely to have the biggest impact on transparency is the
Common Reporting Standard for Automatic Exchange of Information in
Tax Matters ("CRS"), which requires
jurisdictions to obtain information from their financial
institutions and automatically exchange that
