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

28 March 2025

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Treaty Development

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South Africa-United Kingdom

The South Africa Revenue Service (SARS) has published the synthesized text of the tax treaty with the United Kingdom as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized text was prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable. The MLI applies for the 2002 South Africa-United Kingdom tax treaty: with respect to taxes withheld at source on amounts paid or...