Double taxation conventions and protocols Information on the Double Taxation Conventions of the South African Tax Service (SARS), including links to the full text of the conventions. Look at tax rates, the latest tax news and information on double taxation agreements with our specialized online resources, guides and useful links. (2) The imposition of a stable establishment in the other contracting state is no less advantageous in that other state than the taxation applied to the enterprises of that other state that carry out the same activities. 4. If, for any reason, the amount of interest paid is greater than the amount agreed upon by the payer and the actual beneficiary because of a particular relationship between the payer and the actual beneficiary or between the two or another person, the provisions of this section apply only to the amount specified above. In this case, the excess portion of the payments remains taxable under the legislation of each State party, taking due account of the other provisions of this Convention. South Africa: detailed tax agreement of the tax treaties in force between the United Kingdom and South Africa, provided by HMRC. 3. The term “dividends” used in this article refers to income from shares or other rights that are not receivables that are profit-taking, as well as income from other rights of corporations which, according to the legislation of the contracting state in which the company distributing the distribution is subject to the same tax treatment as the income of shares of which the company is a resident , whose dividend payment is considered a dividend or a distribution of a company. (i) the term “international traffic”: any transport by boat or aircraft operated by a company in a contracting state, unless the vessel or aircraft is operated only between locations in another contracting state; 3. The competent authorities of the contracting states endeavour to resolve by mutual agreement any difficulty or doubt about the interpretation or application of this convention.
They can also agree on the elimination of double taxation in cases not provided for by this convention. If this proposal is acceptable to the Government of the Republic of South Africa, I have the honour of proposing that this communication and Your Excellency`s response on this matter be considered an agreement between the two governments on this issue, which will come into force at the same time as the Convention enters into force. 1. Where a resident of a contracting state considers that the actions of one or both contracting states are not taxed for that person in accordance with this Convention, that person may, regardless of the remedies provided by the domestic law of those States, the competent authority of the contracting state, whose resident or, if the case falls under Article 23 , paragraph 1 of this Convention: whose nationality is the person.