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. 3. The term “dividends” used in this article refers to income from shares or other rights that are not claims on profits, as well as income from other rights of corporations that, according to the laws of the contracting state whose distribution is distributed, are subject to the same tax treatment as the income of the shares of which the company resides. 4. The competent authorities of the contracting states may communicate directly with each other in order to reach an agreement in accordance with the preceding paragraphs. We contain a collection of global double taxation conventions in English (and other languages, if available) to assist members in their applications. If you`re having trouble finding a contract, call the application team on (0)20 7920 8620 or email us at firstname.lastname@example.org. The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of South Africa, The provisions of paragraphs 1 and 2 of this article do not apply to income received by a resident of one State Party from activities carried out by the other State party in accordance with paragraphs 1 and 2 of this article, where the visit to that other State is supported, in whole or in part, by public funds of the contracting State. , a political sub-direction or local authority of the latter or takes place as part of an agreement or cultural arrangement between the governments of the contracting states.
In this case, income is taxable only in the first contracting state. Tax Information Guide: Africa`s Leading Economies 2018 Overview of the Tax and Investment Environment in 44 African countries, including Africa. The guide contains income tax rates, withholding tax, a list of double taxation agreements, information on other taxes, investment incentives and important business data. Published by Deloitte in May 2018. I have the honour to refer to the agreement signed today between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of South Africa on the prevention of double taxation and the prevention of tax evasion on income and capital gains, and to present, on behalf of the UK Government, the following proposal: we can provide current and historical tax rates, comparative tables and country surveys via our specific tax databases.