SA lifts long term prohibition on Loop Structures By Supplied Share The South African Reserve Bank (SARB) issued Exchange Control Circular No. 1/2021 to lift the restriction on the so-called ‘loop structure’ in order to encourage inward investments into South Africa. The reform was effective as 1 January 2021 and applies to private individuals and companies, including private equity funds, that are tax resident in South Africa. A loop structure is broadly any arrangement under which a South African resident invests in an offshore vehicle which, in turn, invests in South African assets. Previously such structures were permitted only in very limited instances, such as where SA residents held 40% or less of the shares in a foreign company that held interests back into SA.