In order to promote South Africa as an ideal destination for international capital dedicated to African regional investment, an exception from the effective management test for foreign investment funds has been created. The purpose of the exception is to remove the potential to subject the fund to South African worldwide taxation if the fund is managed by a South African manager. To qualify for this exception from the effective management test, the foreign fund must meet the following criteria: –   the fund must be incorporated, formed or established in a foreign country; –   the fund must operate in...