i What this calculator does
Quick answer: For a South African investor the US-domiciled ETF usually wins slightly on fees and dividend tax, while the Irish one removes the US estate tax exposure above USD 60,000. With the default inputs the calculator returns uS-domiciled, after tax: R5 889 960.
The same S&P 500 can be bought through a US-listed ETF or an Irish-domiciled UCITS ETF listed in London, and for a South African the two are taxed differently in three places: the dividends, the exit and death. A US-domiciled fund pays dividends to you with 15% US withholding if you have a W-8BEN on file, which SARS credits against its own tax. An Irish fund suffers 15% inside the fund under the US–Ireland treaty, and SARS gives no credit for that, but an accumulating version reinvests the rest and defers all South African tax to the sale. And a US-listed ETF is a US-situs asset, so a non-resident who dies holding more than USD 60,000 of it is exposed to US estate tax of up to 40%.
This calculator runs all three routes on your numbers, with fees, the currency spread, the rand’s path, dividend tax at your marginal rate and capital gains tax on exit, and puts a rand figure on the estate tax exposure. Choosing an ETF in the first place is covered in which ETF a South African beginner should buy.
This calculator is for educational purposes only. Results are estimates and may vary depending on market conditions, spreads, commissions, platform settings, and exchange rates. It should not be considered financial advice.
Common results
What the calculator returns as the years held changes, with every other input at its default (amount to invest 1000000, price return a year, in dollars 7, dividend yield 1.3, fund fee, us-domiciled etf 0.03, fund fee, irish-domiciled etf 0.07, currency conversion spread each way 0.5, platform fee a year 0.25, your marginal tax rate 36%).
| Years held | US-domiciled, after tax | Irish accumulating, after tax | US estate tax exposure at the end |
|---|---|---|---|
| 5 years | R1 522 571 | R1 510 956 | R133 346 |
| 10 years | R2 364 349 | R2 332 936 | R383 250 |
| 15 years | R3 716 855 | R3 651 808 | R826 195 |
| 20 years | R5 889 960 | R5 767 943 | R1 585 679 |
| 25 years | R9 381 542 | R9 163 295 | R2 883 977 |
| 30 years | R14 991 555 | R14 611 154 | R5 068 871 |
Figures used in this calculator
The South African constants this calculator relies on, with the page that holds the current value and the date it was last verified.
- Foreign dividends: Taxed on 20/45 of the amount, maximum 20%. Source: Interest and Dividend Tax Exemptions (verified 29 September 2026).
- US dividend withholding: 30%, or 15% with a valid W-8BEN. Source: Dividend Withholding Tax Rates by Country (verified 27 September 2026).
- Capital gains tax: 40% inclusion, R50,000 annual exclusion (2026/27). Source: Capital Gains Tax Rates and Exclusions (verified 15 October 2026).
- Offshore allowances: R2 million SDA and R10 million FIA a calendar year. Source: SDA and FIA Offshore Allowances (verified 27 September 2026).
Where the dividend tax goes
SARS taxes foreign dividends on 20/45 of the amount at your marginal rate, an effective 20% at the 45% bracket and 16% at 36%. On a US-domiciled ETF the 15% US withholding is credited against that, so the total is the higher of the two. On an Irish distributing ETF the 15% is lost inside the fund and the South African tax comes on top, about 28.6% in total at a 36% marginal rate. An Irish accumulating ETF pays the 15% inside and nothing in South Africa until you sell. With a dividend yield near 1.3%, these differences move the result by a few basis points a year; the fund fee difference is of the same order.
The estate tax that decides it for larger portfolios
A non-resident’s US-situs assets above USD 60,000 are taxed by the US at death on a scale that reaches 40% above USD 1 million, with no marital deduction. South Africa has an estate tax agreement with the US dating from 1947, and SARS gives a credit against South African estate duty for foreign death duties on the same assets, but that credit only stops the same assets being taxed twice; it does not remove the US tax. The calculator shows the exposure at the end of your holding period; for a portfolio of a few hundred thousand dollars it typically outweighs every fee and dividend difference combined.
Reading the result
If the US-domiciled route wins only by a small margin while carrying a large estate tax figure, the Irish accumulating ETF is usually the better default for a long-term holding. If the amount will stay under USD 60,000, or the holding is short, the cheaper US fund can make sense. Either way, a W-8BEN halves the US withholding on US-domiciled funds, and the currency spread on the way in and out matters more than either fund fee.
Spotted an outdated figure? If a rate, limit or formula in this calculator no longer matches its source, email us the page and the source. A material correction is dated on the Updates Log.
Frequently asked questions
Should a South African buy VOO or CSPX?
They track the same index. VOO is US-domiciled, cheaper and distributes; CSPX is Irish-domiciled and accumulates. For a long-term South African holder CSPX avoids US estate tax and defers SA dividend tax, which usually outweighs VOO’s lower fee; the calculator shows the trade-off on your numbers.
Do South Africans pay US estate tax on US shares?
Yes, on US-situs assets above USD 60,000 at death, at rates up to 40%. US-listed shares and ETFs are US-situs; Irish-domiciled ETFs are not, even when they hold US shares.
How are foreign dividends taxed in South Africa?
20/45 of the dividend is taxed at your marginal rate, which caps the effective rate at 20%. Foreign withholding tax paid directly on the dividend is credited against it, up to the SA tax on that dividend.
What is a W-8BEN and do I need one?
A US tax form that confirms you are not a US person and claims the treaty rate. With it the US withholds 15% on dividends instead of 30%. Offshore brokers usually ask for it at account opening; it must be renewed every three years.
Does an accumulating ETF avoid South African tax?
It defers it. No dividend is paid, so there is no dividend tax each year, but the reinvested income is in the price and is taxed as a capital gain when you sell, at a lower effective rate than dividends.
Does buying offshore ETFs use my offshore allowance?
Yes if you move rand offshore to buy them: the R2 million single discretionary allowance or, with SARS approval, the R10 million foreign investment allowance. Rand-denominated feeder funds and JSE-listed ETFs that track the same index do not use the allowance.
Want to embed this calculator on your site?
Embed this calculator
Free to use on your own site. Copy the code below and paste it where you want the calculator to appear.
<iframe src="https://www.tradeanswers.co.za/embed/us-vs-irish-etf-calculator.html"
width="100%" height="1000" style="border:0;max-width:520px"
title="US vs Irish-Domiciled ETF Calculator - TradeAnswers" loading="lazy"></iframe>
<p><a href="https://www.tradeanswers.co.za/us-vs-irish-etf-calculator.html">US vs Irish-Domiciled ETF Calculator</a> by <a href="https://www.tradeanswers.co.za/">TradeAnswers</a></p>