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Treaty between Australia and South Africa – new protocol signed

14 May 2008

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Treaty Development

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Australia-South Africa

On 31 March 2008, Australia's High Commissioner in South Africa and the acting Minister of Finance in South Africa signed a protocol to the existing 1999 tax treaty between Australia and South Africa, which revises the existing treaty as follows: -   dividend withholding tax for non-portfolio dividends received by a corporate entity is reduced from 15% to 5%. The rate remains 15% for other dividends; -   interest withholding tax remains at 10%, but is reduced to nil where interest is paid to an unrelated financial institution, unless the loan was made under a back-to-back arrangement; -   royalty...