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Up Double Taxation Agreements

Agreements aimed at eliminating double taxation of income between South Africa and specific countries are of two types:

The process of reaching an effective agreement takes place in three phases:

  • Phase one is the process of exploration and negotiation;
  • Phase two is the signing of the agreement by both countries;
  • Phase three is the ratification of the agreement. Each country must ratify the agreement before it can be operational.

COMPREHENSIVE AGREEMENTS (covers income from all sectors)

COUNTRY GAZETTE NO EFFECTIVE
Austria 17965 1997
Botswana # R49 1978
Canada 17985 1997
Denmark 16891 1995
Finland 16862 1995
France 16681 1995
Germany R125 1973
Hungary 17438 1996
Grenada * R229 1946
Israel R139 1979
Japan R372 1968
Korea (South) 16918 1996
Lesotho 17948 1997
Malawi R176 1971
Mauritius 18111 1997
Namibia # R2027 1969
The Netherlands R140 1971
Norway 17504 1996
Poland 17201 1995
Republic of China 17408 1996
Romania 16680 1995
Seychelles * R229 1946
Sierra Leone * R229 1946
Swaziland # R70 1973
Sweden 16890 1995
Switzerland R240 1967
Thailand 17409 1996
United Kingdom R138 1969
Zambia # R174 1956
Zimbabwe # R214 1965
* these countries were colonies of the United Kingdom and the agreement was extended to these countries.

# original agreements with these countries are being revised

LIMITED AGREEMENTS (covers income from air and sea operators)

COUNTRY GAZETTE NO EFFECTIVE
Belgium + R270 1957
Brazil R137 1972
Greece + R17 1965
Ireland + R302 1960
Italy + R217 1953
Portugal R324 1957
Spain R33 1974

+ agreements with these countries are being upgraded from a limited agreement to a comprehensive agreement.

The following comprehensive agreements have been signed by both countries but have only been ratified by South Africa.
They will only be effective once the agreement has been ratified by the relevant countries:

Comprehensive agreements with the following countries have been signed by both countries and are awaiting ratification by both South Africa and the relevant countries:

Comprehensive agreements that are under negotiation and have not been signed:

[ Last Modified: 28-Aug-1998 | Legal Disclaimer ]
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