Key exemptions, exclusions and relief measures include the following: a) residents who together with connected parties hold less than 10% of the participation and voting rights b)a high tax exemption where the taxes payable in a foreign jurisdiction at least equal 75% of the South African taxes which would have payable had the foreign resident been a South African resident. c) certain companies falling under the headquarter company rules. d) income or taxable income which is already taxed in South Africa. e) relief from foreign taxes paid by the CFC.