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South Africa: Double Tax Treaties

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South Africa Introduction

A double tax treaty allows that tax paid can be offset in one of two countries against tax payable in the other, thus avoiding double taxation. South Africa is a signatory to double tax treaties with several countries throughout the world. Some forms of income are exempt from tax or qualify for reduced rates. These include royalties, dividends and capital gains.

The following is a list of countries with which South Africa has signed a double tax treaty. All information detailed below is correct as at March 1, 2010.

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South Africa Table of Double Tax Treaties

Country
Effective from (year)
Country
Effective from (year)
Algeria
2000
Malaysia
2006
Australia
1999
Malta
1997
Austria
1997
Mauritius
1997
Belarus
2003
Mozambique
2009
Belgium
1998
Namibia
1999
Botswana
2004
Netherlands
1972/2008
Brazil
2006
New Zealand
2004
Bulgaria
2004
Nigeria
2008
Canada
1997
Norway
1996
China (PRC)
2001
Oman
2003
Croatia
1997
Pakistan
1999
Cyprus
1998
Poland
1995
Czech Republic
1997
Portugal
2008
Denmark
1995
Romania
1995
Egypt
1998
Russian Federation
2000
Ethiopia
2006
Saudi Arabia
2008
Finland
1995
Seychelles
2002
France
1995
Singapore
1997
Ghana
2007
Slovak Republic
1999
Germany
1975*
Spain
2007
Greece
2003
Swaziland
2005
Hungary
1996
Sweden
1995
India
1997
Switzerland
1968/2009
Indonesia
1998
Taiwan
1996
Iran
1998
Tanzania
2007
Ireland
1997
Thailand
1996
Israel
1980
Tunisia
1999
Italy
1999
Turkey
2006
Japan
1997
Uganda
2001
Korea
1996
Ukraine
2004
Kuwait
2006
United Kingdom
2002
Lesotho
1997
USA
1997
Luxembourg
2000
Zambia
1956
Malawi
1971
Zimbabwe
1965

* Renegotiated and signed in 2008, but ratified in South Africa only.

Treaties are in the process of negotiation or have been finalized, but not yet signed, with Angola, Bangladesh, Bahrain, Cameroon, Chile, Cuba, Estonia, Kenya, Latvia, Lithuania, Madagascar, Morocco, Qatar, Senegal, Serbia, Sri Lanka, Syria, United Arab Emirates and Vietnam. Also, agreements have been signed with the following countries, but not yet ratified: Democratic Republic of Congo, Gabon, Mexico, Rwanda and Sudan.

South Africa also has estate duty agreements with Botswana, Lesotho, Swaziland, Zimbabwe, the United Kingdom and the USA.

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South Africa Other International Agreements

South Africa has customs agreements on mutual administrative assistance with Algeria, China, France, India, Mozambique, The Netherlands, the United Kingdom and the USA. Similar agreements have been ratified in South Africa only, with the following countries: Brazil, the Czech Republic, the Democratic Republic of Congo, Iran, Norway, Sudan, Turkey and Zambia. Another has been signed with Canada but is not yet ratified.

Tax co-operation agreements have been signed with India and Brazil.

South Africa is in the process of negotiating, or has negotiated but not yet signed, tax information exchange agreements with the Bahamas, Bermuda, the British Virgin Islands, the Cayman Islands, Gibraltar, Guernsey, Jersey, Liechtenstein, Monaco, the Netherlands Antilles and San Marino.

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