On 30 September 2022, South Africa deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Based on the date of deposit, the MLI will enter into force for South Africa on 1 January 2023, although its entry into force for South Africa's covered agreements (tax treaties) will depend on the ratification of the MLI by the counterparty to a particular covered agreement. The MLI will generally enter into force for a particular covered agreement on the first day of the month following a three-month period after...