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South Africa Publishes Revised Synthesized Text of Tax Treaty with Finland as Impacted by the BEPS MLI

07 February 2024

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Treaty Development

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South Africa-Finland

The South African Revenue Service (SARS) has published a revised synthesized text of the tax treaty with Finland as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The revisions were made considering Finland's updated (consolidated) MLI position that was deposited on 27 June 2023. Finland's updated position includes the withdrawal of Finland's reservation regarding MLI Article 9 – Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property, as well as a notification to apply optional Article 9(4) of the MLI, which...