Can you keep your South African share portfolio after aliyah?
You can keep the shares; the harder question is whether you can keep the account. Once you become a non-resident, most South African brokers will not let you carry on a normal resident trading account: you typically have to re-designate it as a non-resident account (often a narrower offering) or close it and sell. So the real decision for an oleh is whether to sell the JSE portfolio before you fly or move the broker relationship across, and the tax cuts the opposite way to what most new olim expect: direct JSE shares usually fall out of South African capital-gains tax for a non-resident, while a one-off section 9H exit charge can tax the built-in gain when you cease residency12.
Not advice
Almost every new South African oleh assumes the South African Revenue Service (SARS) will chase the gain on their JSE shares forever, the way it chases a flat in Sandton. For listed shares it is the reverse. The exposure that actually bites is a single deemed disposal on the day you leave, not an open-ended claim on future sales. This article keeps the three layers separate and labeled: the South African side (situs, the exit charge, and keeping or closing the broker account), the Israeli side (the oleh exemption on foreign gains), and the exchange-control path for getting the proceeds to your Israeli account. It then handles the one trap that flips all of this for a US-South African dual: PFIC.
South African side: are JSE shares taxed in SA after you leave?
Generally not, once you are a non-resident. South African capital-gains tax reaches a non-resident only on immovable property situated in South Africa (and on assets of a South African permanent establishment)1. Direct JSE-listed shares are movable property and are notSouth-African-situated for CGT purposes in a non-resident's hands, so when a non-resident sells them the gain is typically outside SA CGT1. That is the sharp contrast with property: your Johannesburg house stays inside SA CGT and triggers the Section 35A withholding on sale, but your JSE share portfolio does not.
So what is the section 9H exit charge, and why does it still catch the shares?
Because South Africa charges you once, on the way out. When you cease to be a South African tax resident, section 9H of the Income Tax Act deems you to have disposed of your worldwide assets at market value the day before you cease, and to have reacquired them at that value the next day2. This is the SA exit tax. It pulls your JSE shares into one final SA capital-gains calculation based on their value at the cessation date, even though an ordinary future sale by a non-resident would not be taxed. Critically, the exit charge excludes SA immovable property, precisely because that property never leaves the SA net in the first place2. So the two regimes dovetail: property is taxed on the actual sale (and withheld under Section 35A); shares are taxed once, at exit, under section 9H.
What does the SA capital-gains math look like?
For a natural person, SARS applies a R50,000 annual exclusion and a maximum effective CGT rate of about 18% on the taxable gain1. The section 9H exit charge runs through that same machinery: it is an ordinary CGT event, just triggered by cessation rather than by a sale, so the rate, the annual exclusion, and the assessment all work the normal way2. The practical point for an oleh is that the gain frozen on your exit date is the SA number that matters; what your shares do afterwards is, for SA CGT on direct listed shares, generally irrelevant.
Can you keep the brokerage account as a non-resident?
Often only in a re-designated form. South African brokers operate within South African Reserve Bank (SARB) exchange-control rules, and once you cease residency your account changes character: funds you hold in South Africa as a non-resident are treated differently, and many brokers either move you to a non-resident account with a narrower set of permissions or ask you to close it3. Some olim keep a non-resident JSE account open and sell gradually; others close out entirely so the whole portfolio becomes cash that can be moved in one exchange-control exercise. Either way, the re-designation is an administrative step you should raise with the broker before you cease residency, not after, because a frozen or non-compliant account stalls the eventual transfer.
| Asset | In SA CGT after you are non-resident? | Caught by the section 9H exit charge? |
|---|---|---|
| Direct JSE-listed shares | Generally no (not SA-situated for a non-resident)1 | Yes, deemed disposed at market value on cessation2 |
| SA immovable property (a house or flat) | Yes, always (and Section 35A withholds on sale)1 | No, excluded from the exit charge2 |
| SA unit trust / JSE-listed ETF (a pooled fund) | Generally no for SA CGT, but see the US PFIC trap below1 | Yes, caught by section 9H at exit2 |
Worked example: a R3 million JSE portfolio
Suppose you hold a R3 million portfolio of direct JSE shares, with a base cost of R1.8 million, so a built-in gain of R1.2 million. You make aliyah and cease SA tax residency.
South African side. On cessation, section 9H deems you to have sold the whole portfolio at its R3 million market value the day before you cease, crystallising the R1.2 million gain in South Africa2. After the R50,000 annual exclusion, that gain runs through SA CGT at a maximum effective rate of about 18%1. That is your SA tax, paid once. If you then keep the shares as a non-resident and sell them a year later for R3.3 million, the further R300,000 of gain is generally outside SA CGT, because a non-resident is not taxed on disposing of non-SA-situated movable assets like listed shares1.
Israeli side. As a new עולה חדש (oleh chadash), your foreign-source income and gains are generally exempt from Israeli מס הכנסה (mas hachnasa) for ten years5. So that R300,000 later gain on your JSE shares is, inside the 10-year window, generally Israel-exempt as well: South Africa already let it go, and Israel does not tax it during the exemption period. The contrast is the whole story: South Africa taxes once at the door (section 9H) and then steps back from listed shares; Israel holds the door open for ten years on foreign gains.
How is a new oleh taxed on foreign-share gains in Israel?
A new oleh receives a 10-year exemption on foreign-source income and capital gains, which covers gains on shares held and sold abroad, including JSE shares5. Inside that window, a sale of your South African portfolio is generally not an Israeli taxable event. One change to flag: from 1 January 2026° a reporting reform makes some still-exempt foreign income and gains reportable to the Israel Tax Authority. It stays exempt from tax for the affected arrivals; you simply now have to declare it rather than stay silent5. Do not read "exempt" as "invisible" under the new rules.
Outside the 10-year window, or for olim the reform fully catches, Israel can tax a foreign capital gain in the ordinary way, and where South Africa also taxed part of it the SA-Israel tax treaty provides relief from double taxation through a credit mechanism. Because the SA side on direct listed shares is usually settled once at exit, the realistic Israeli exposure for most share-holding olim is a gain that accrues after exit and is sold after the 10-year window closes. Keep the SA exit-date valuation; it becomes your cost reference for measuring any later gain.
The PFIC trap: direct shares are fine, pooled funds are not
Everything above assumes you hold direct JSE shares. If you are also a US citizen or green-card holder, that distinction is the difference between a clean move and a punitive one. A US person keeps filing US returns on worldwide income for life, wherever they live7, and the US treats almost every non-US pooled fund as a Passive Foreign Investment Company (PFIC). A South African unit trust, a JSE-listed ETF, or a money-market fund is a PFIC: under the default IRC §1291 method the gain is taxed at the highest historic ordinary rates plus an interest charge, and each fund needs its own annual Form 86216.
So for a US-South African dual the portfolio splits in two. Direct JSE shares carry no PFIC problem; you can hold or sell them on the normal US rules. But every SA unit trust or ETF in the account is a PFIC, and the US tax on it can dwarf both the SA exit charge and any Israeli figure. The cross-border move is to identify and deal with the pooled funds before you move, typically by selling them while the numbers are still manageable and reinvesting through US-domiciled funds, rather than carrying PFICs into Israel and discovering Form 8621 at the next US filing. This is the textbook case where the right advice for a native South African investor (own the local unit trust) is the opposite of the right advice for a US-South African oleh.
How do you get the proceeds to Israel through exchange control?
Selling the shares is one step; moving the cash is another, and South Africa still runs exchange control. The proceeds leave through an Authorised Dealer bank under SARB rules: up to R2 million per calendar year on the single discretionary allowance with no SARS clearance (doubled from R1 million on 8 April 2026), and from R2 million up to R10 million per year on the foreign capital allowance, which needs an Approval for International Transfer (AIT) PIN from SARS plus proof of source of funds and tax compliance34. A R3 million share sale therefore needs an AIT for the R1 million portion above the R2 million allowance, so build the source-of-funds file (broker statements showing the holdings and the sale) alongside the disposal. The detailed SARB-and-AIT mechanics and the conversion-cost question are covered in the dedicated transfer article on this site; treat the share sale and the rand transfer as two linked but separate stepsמטבע חוץ (matbea chutz).
Sell before you fly, or move the broker across?
There is no single right answer, but the trade-offs are clear. Selling before aliyah is the clean option: you convert the whole portfolio to cash, deal with the account closure and the exchange-control transfer once, and arrive with shekels you can redeploy. The cost is that you crystallise the position on SA timing, and if you are a US person you may pay US tax on any gain in the year of sale. Holding and moving the broker across keeps you invested through the transition and lets you sell gradually as a non-resident, often outside SA CGT for direct shares1. The cost is a more limited non-resident account, ongoing currency-and-reporting admin, and, for a US person, the PFIC exposure on any pooled funds you do not clear out first6. The section 9H exit charge applies either way, because it is triggered by ceasing residency, not by selling2.
Direct JSE-listed shares generally fall out of South African capital-gains tax once you are a non-resident, so the gain that bites is a one-off section 9H exit charge on the day you cease SA tax residency. On the Israeli side a new oleh gets a 10-year exemption on foreign-source gains. Move the proceeds through a SARB Authorised Dealer: up to R2 million a year on the single discretionary allowance with no clearance, and above that, up to R10 million, on the foreign capital allowance with a SARS AIT PIN.
Generally not, once you are a non-resident. A non-resident is liable to SA CGT only on SA immovable property and on assets of a SA permanent establishment, and direct JSE-listed shares are neither, so a later sale by a non-resident is typically outside SA CGT. The gain that does get taxed is the one frozen on your exit date under the section 9H deemed disposal.
It is South Africa’s exit tax. When you cease SA tax residency, you are treated as having sold your worldwide assets at market value the day before you cease and reacquired them at that value, so the gain built up to that date is taxed once on the way out. Your JSE shares are caught; your SA immovable property is specifically excluded.
Sometimes, but usually only after the broker re-designates it as a non-resident account, which often comes with narrower permissions; some brokers ask non-residents to close instead. Raise it with your broker before you cease residency, because an account left in the wrong status can stall the eventual exchange-control transfer of the proceeds.
Inside your first ten years as a new oleh, foreign-source gains, including on JSE shares, are generally exempt from Israeli tax. From 1 January 2026 some of that still-exempt income and gain becomes reportable to the Israel Tax Authority; it remains tax-exempt for the affected arrivals but must be declared.
Yes. A South African unit trust, a JSE-listed ETF, or a money-market fund is a PFIC for a US person, taxed punitively under the default IRC §1291 method with an interest charge and an annual Form 8621 per fund. Direct JSE shares are not PFICs. The usual move is to deal with the pooled funds before you move and reinvest through US-domiciled funds, with cross-border advice.
Through a SARB Authorised Dealer: up to R2 million a year on the single discretionary allowance with no clearance (doubled from R1 million on 8 April 2026), and from R2 million up to R10 million on the foreign capital allowance, which needs a SARS Approval for International Transfer PIN plus proof of source of funds. The transfer mechanics are covered in full in the dedicated rand-transfer article on this site.
