DT17350 - Double Taxation Relief Manual: Guidance by country: South Africa: Agreement

»Ê¹ÚÌåÓýapp comprehensive agreement (SI 2002/3138) entered into force on 17 December 2002 and has effect:

a) In the United Kingdom for corporation tax from 1 April 2003 and for income tax and capital gains tax from 6 April 2003.

b) In South Africa from 1 January 2003.

A protocol amending the 2002 agreement (SI 2011/2441) entered into force on 13 October 2011. It amends the dividend and exchange of information articles and introduces an article on assistance in collection. »Ê¹ÚÌåÓýapp protocol has effect in respect of exchange of information and assistance in collection for requests made on or after the date of entry into force. »Ê¹ÚÌåÓýapp provisions relating to dividends entered into force on 1 April 2012, the date on which South Africa introduced a system of taxation at shareholder level for dividends declared.

If using the HMRC Intranet, the agreement and protocol can be viewed through the “New treaties/protocols in force� link on the sidebar. On the HMRC web-site, searching for “Treaties in force South Africa� will provide a link to the agreement.

»Ê¹ÚÌåÓýapp text of the Tax Treaty can be found via /government/publications/south-africa-tax-treaties