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A protocol amending the UK's double taxation convention with South Africa was signed in Pretoria on 8 November.
South Africa is changing its system of taxing dividends paid to non-residents by abolishing its secondary tax on companies and introducing a withholding tax.
The protocol amends the provisions of the convention dealing with the taxation of dividends to set limits to the withholding tax. It also updates the provisions dealing with the exchange of information between the UK and South Africa and introduces a new provision regarding assistance in the collection of taxes.
The protocol will enter into force once both countries have completed their legislative procedures and will take effect in both countries in respect of dividends from the date that South Africa changes its system of taxation at the shareholder level and for the other provisions from the date that it enters into force.
