South Africa: Tax Treaties

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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.

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

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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...

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ENS

Understanding The Complexities Of Offshore Investments For South Africans

In an increasingly globalised economy, many South Africans are exploring offshore investments as a way to diversify their portfolios and mitigate local economic risks

South Africa Government

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The Sovereign Group

Africa Tax In Brief

Following the signing of the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI) by Benin, Cabo Verde and the Democratic Republic of the Congo

South Africa Tax

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

Africa Tax In Brief

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

New Remote Working Visa Proposed

South Africa Immigration

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

ENS Tax In Brief

South Africa Tax

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ENS

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

South Africa Tax

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ENS

Tax In Brief | Issue 103

South Africa Tax

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ENS

Africa Tax In Brief

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ENS

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

South Africa Tax

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ENS

Disney vs. OpenAI - When IP Meets Generative AI

South Africa Technology

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ENS

AFCON Eliminations: Celebrating African Football And Intellectual Property Development

South Africa IP

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Adams & Adams

Constructive Dismissal Arising From Remote Working Dispute: Lessons For Employers

South Africa Employment

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ENS

Arbitrators Cannot Decide Constitutional Invalidity In Public Procurement

South Africa Government

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ENS

Lessons From 2025, Directions For Tomorrow

South Africa Commercial

SG

SNG Grant Thornton

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

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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

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ENS

MLI Ratification

The MLI will not function in the same way as an amending protocol to a bilateral double tax agreement (DTA) which directly amends the text of the specific DTA. Instead,...

South Africa Tax

SG

SNG Grant Thornton

The Tax Challenges Of International Remote Work

Due to the impact of the COVID-19 pandemic, many employers have seen an increased demand for international remote working arrangements. We have briefly touched upon...

South Africa Tax

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ENS

BEPS MLI Submitted To Parliament For Ratification

South Africa Tax

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SNG Grant Thornton

Tax In Brief | Issue 78

South Africa Tax

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ENS

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

South Africa Tax

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ENS

Tax In Brief Issue 77

South Africa Tax

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

Tax In Brief | Issue 73

South Africa Tax

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ENS

Africa Tax In Brief

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ENS

Tax In Brief | Issue 61

South Africa Tax

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ENS

Important Tax Developments Of The Post-BEPS World

South Africa Tax

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Bowmans

Africa Tax In Brief

South Africa Tax

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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)...

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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

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ENS

Important Tax Developments Of The Post-BEPS World

Tax law is subject to frequent change.

South Africa Tax

B

Bowmans

Africa Tax In Brief

AFRICA: African Tax Administration Forum publishes COVID-19 Pandemic Tax Administration and Policy Developments Guide

South Africa Tax

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ENS

ENSafrica Tax In Brief - Issue 44

South Africa Tax

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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

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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

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DLA Piper UK LLP

Africa Tax In Brief - 21 May 2019

The Parliament of Zimbabwe and the Ethiopian House of Representatives approved the African Continental Free Trade Area Agreement

South Africa Tax

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ENS

Tax Revenews - Issue 20

whether a receipt by the appellant taxpayer in respect of a lease premium was of a revenue nature or a capital nature, considered.

South Africa Tax

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ENS

Africa Tax In Brief - August 2018

South Africa Tax

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ENS

Africa Tax In Brief - May 2018

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ENS

Africa Tax In Brief - January 2018

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ENS

Africa Tax In Brief - October 2017

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ENS

Africa Tax In Brief - November 2017

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ENS

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

South Africa Tax

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Fasken

Africa Tax In Brief - August 2017

South Africa Tax

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ENS

Africa Tax In Brief

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ENS

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

South Africa Tax

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Pieter van der Zwan & Associates

South African Budget 2017: Business Perspective

South Africa Tax

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Pieter van der Zwan & Associates

South African Budget: Wealth And Investment Perspective

South Africa Tax

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Pieter van der Zwan & Associates

Africa Tax In Brief – 20 September 2016

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ENS

Africa Tax In Brief - 19 July 2016

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ENS

OECD Request For Input On The Development Of A Multilateral Instrument To Implement Tax Treaty BEPS Measures

South Africa Tax

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ENS

Africa Tax In Brief - 27 Apr 2016

South Africa Tax

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ENS

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