South Africa: Tax Treaties

Subscribe

Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Binding Private Ruling 430 And Trust-to-trust Distributions

South Africa's Revenue Service has issued Binding Private Ruling 430, clarifying its position on trust-to-trust distributions and the section 7(8) attribution rules. The ruling examines whether distributing an interest-free loan claim constitutes a disposition, explores how the causal nexus can be severed when downstream yields are generated by independent foreign companies, and reveals the administrative complexities trustees face when claiming foreign tax rebates for non-resident beneficiaries.

South Africa Tax

CD

Cliffe Dekker Hofmeyr

Tax Focus - June 2026 Issue

South Africa's tax landscape is evolving with new border control requirements, refined R&D incentives, and recent SARS rulings on mining rehabilitation and equity structures. What do these developments mean for businesses operating across borders and claiming tax relief?

South Africa Tax

SG

SNG Grant Thornton

Remote Work And PE: What The OECD's New Framework Clarifies, And What It Leaves Unresolved

The 2025 Update to the OECD Model Tax Convention Commentaries provides guidance on when a home or remote location can give rise to a fixed place of business PE under Article 5(1).

South Africa Tax

WW

Webber Wentzel

Africa Tax In Brief

On 29 April 2025, the African Tax Administration Forum ("ATAF") announced that it has commenced a review of its ATAF Income Model Convention (2019), aimed at strengthening the ability of African countries to negotiate tax...

E

ENS

Understanding The Complexities Of Offshore Investments For South Africans

South Africa Government

TS

The Sovereign Group

Africa Tax In Brief

South Africa Tax

E

ENS

Africa Tax In Brief

South Africa Tax

E

ENS

Africa Tax In Brief

E

ENS

Africa Tax In Brief

South Africa Tax

E

ENS

New Remote Working Visa Proposed

South Africa Immigration

E

ENS

Africa Tax In Brief

South Africa Tax

E

ENS

ENS Tax In Brief

South Africa Tax

E

ENS

Foreign Employers Warned Ahead Of Proposed Changes In Employee Tax And Withholding Obligations In South Africa

South Africa Tax

E

ENS

Tax In Brief | Issue 103

South Africa Tax

E

ENS

The Trade Mark That Refused To Die: Deadwood Or Zombie?

South Africa IP

AA

Adams & Adams

Africa Tax In Brief

South Africa Tax

E

ENS

After The Freeze: What Happens Next For Crypto Arbitrage And Exchange Control Risk?

South Africa Finance

E

ENS

Cash Is Not Disappearing - Why The South African Reserve Bank’s Cash Smart Strategy Matters For South Africa’s Payment Future

South Africa Finance

E

ENS

Crypto Crackdown: What The Reserve Bank’s Case Against Kastelo Means For Your Business

South Africa Finance

E

ENS

Africa Tax In Brief

The African Union's Specialized Technical Committee on Finance, Monetary Affairs, Economic Planning and IntegraAtion recently reiterated its stance that the qualified domestic minimum...

E

ENS

Curbing Tax Evasion: The OECD Publishes Its Latest Report On Treaty Shopping

On 31 May 2022, the OECD published its Fifth Peer Review Report on Treaty Shopping. The report includes extensive information on tax treaties concluded by the countries...

South Africa Tax

E

ENS

ENSafrica Tax In Brief - Issue 99

Below, please find issue 99 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa Tax

E

ENS

What Is Inside The New Rwanda Tax Procedure Law?

Effective from 31 March 2023, Rwanda has a new law on tax procedures (see here) as part of tax reforms the country has embarked on in the last few years.

South Africa Tax

E

ENS

MLI Ratification

South Africa Tax

SG

SNG Grant Thornton

The Tax Challenges Of International Remote Work

South Africa Tax

E

ENS

BEPS MLI Submitted To Parliament For Ratification

South Africa Tax

SG

SNG Grant Thornton

Tax In Brief | Issue 78

South Africa Tax

E

ENS

The Anti-Global Base Erosion Rules Released: What It Means For MNE Taxation

South Africa Tax

E

ENS

Tax In Brief Issue 77

South Africa Tax

E

ENS

Africa Tax In Brief

South Africa Tax

E

ENS

Tax In Brief | Issue 73

South Africa Tax

E

ENS

Africa Tax In Brief

E

ENS

Tax In Brief | Issue 61

South Africa Tax

E

ENS

Africa Tax In Brief

The African Tax Administration Forum ("ATAF") on 8 October 2021 issued a statement commenting on the progress made towards the OECD global tax agreement that envisages...

South Africa Tax

E

ENS

Tax In Brief | Issue 73

Below, please find issue 73 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa Tax

E

ENS

Africa Tax In Brief

The African Tax Administration Forum ("ATAF") has issued a statement commenting on the application of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS)...

E

ENS

Tax In Brief | Issue 61

Below, please find issue 61 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa Tax

E

ENS

Important Tax Developments Of The Post-BEPS World

South Africa Tax

B

Bowmans

Update On The Application Of The Most Favoured Nation Clause In The South Africa And Netherlands Tax Treaty

On 12 June 2019 the Tax Court in Cape Town upheld the application of the most favoured nation clause in the double taxation agreement (DTA) concluded between South Africa and the Netherlands

South Africa Tax

B

Bowmans

Tax In Brief - Issue 33

Below, please find issue 33 of ENSafrica's tax in brief, a snapshot of the Below, please find issue 33 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa Tax

E

ENS

A Tale Of Three DTA's: South African Tax Court Confirms That No Dividends Tax Is Payable On Distributions To Dutch Resident Shareholders

In terms of section 64E(1)(a) of the Income Tax Act 58 of 1962 ("the ITA") dividends tax at a rate of 20% must be paid when a South African company declares and pays a dividend.

South Africa Tax

F

Fasken

South African Tax Court Confirms Application Of The Most Favoured Nation Clause In The South Africa / Netherlands Treaty

In our Global Tax Alerts in February 2018 and January 2019 we discussed the Dutch Court of Appeal's decision which held that dividend distributions from Dutch entities to South African entities are effectively...

South Africa Tax

DP

DLA Piper UK LLP

Africa Tax In Brief - 21 May 2019

South Africa Tax

E

ENS

Tax Revenews - Issue 20

South Africa Tax

E

ENS

Africa Tax In Brief - August 2018

South Africa Tax

E

ENS

Africa Tax In Brief - May 2018

E

ENS

Africa Tax In Brief - January 2018

E

ENS

Africa Tax In Brief - October 2017

E

ENS

Africa Tax In Brief - November 2017

E

ENS

Treasury Proposes New Rules Dealing With The Tax Treatment Of The Conversion Of Debt Into Equity

South Africa Tax

F

Fasken

Africa Tax In Brief - August 2017

South Africa Tax

E

ENS

Africa Tax In Brief

E

ENS

South African DTAs: Most-Favoured-Nation Clauses Relating To Tax On Dividends

South Africa Tax

Pv

Pieter van der Zwan & Associates

South African Budget 2017: Business Perspective

South Africa Tax

Pv

Pieter van der Zwan & Associates

South African Budget: Wealth And Investment Perspective

South Africa Tax

Pv

Pieter van der Zwan & Associates

Africa Tax In Brief – 20 September 2016

E

ENS

Africa Tax In Brief - 19 July 2016

E

ENS

See more

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More