The withholding tax on dividends is 0% if the receiving company owns directly at least 10% of the capital of the distributing company. The protocol to the treaty contains a provision allowing South Africa to levy a 5% branch profit tax (but not if a permanent establishment becomes subject to the secondary tax on companies). Deviations from the OECD Model include: -   Art. 4 Residents: the treaty also applies to exempt pension funds that are recognized and controlled according to the statutory provisions of a contracting state -   Art. V Protocol Ad Art. 7 (Business profits): payments received...