UK, South Africa Amend Double Tax Treaty

by Amanda Banks, Tax-News.com, London

17 November 2010

The UK tax authority, HM Revenue and Customs has announced the signing of a protocol to the convention for the avoidance of double taxation the UK shares with South Africa. The protocol was co-signed by Pravin Gordhan, the South African Minister for Finance, and Nicola Brewer, the British High Commissioner in South Africa, at a ceremony in Pretoria on November 8, 2010.

The amendment has been made on the request of South Africa which 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 rates of withholding tax. It also updates the provisions dealing with the exchange of information between the United Kingdom 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.

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