OrbitaxGeneral ruling – dividends tax covered under article 2 of South African tax treaties
|Treaty Development|South Africa
The South African Revenue Service (SARS) issued a binding general ruling on 19 February 2013 dealing with the question as to whether the "dividends tax" introduced on 1 April 2012 is covered under South Africa's tax treaties that were signed before that date. Details of the ruling are summarized below.
(a) Background. Prior to 1 April 2012, South Africa had a so-called secondary tax …
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