Cessation of South African residency: A critical analysis of juridical double taxation on United Kingdom immovable property held by natural persons

Abstract

When a natural person ceases to be resident, there is a deemed disposal of worldwide assets, and a capital gain must be calculated. Taxation levied because of a change in residence is referred to as an exit tax. In this context, juridical double taxation could arise if the assets are taxed in both the previous and the new state of residence.