OrbitaxOrbitax

Sweden Clarifies Limited Application of MFN Clause Under Tax Treaty with South Africa

|Treaty Development|Sweden-South Africa
Sweden-South Africa

On 18 March 2025, the Swedish Tax Agency published updated guidance regarding the application of the MFN clause in the 1995 tax treaty with South Africa. The MFN clause concerns the withholding tax rate on dividends, which was triggered by South Africa's 2004 tax treaty with Kuwait, providing a withholding tax exemption on dividends effective 1 January 2012. While the guidance previously provi…

Continue Reading