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 provided that this exemption provided to dividends in general under the Sweden-South Africa tax treaty, the update provides that the MFN clause was only triggered with respect to paragraph 2(a) of Article 10 (Dividends), meaning the exemption only...