Details of the Kenya - South Africa Income Tax Treaty (2010), signed on 26 November 2010, have become available. The treaty was concluded in the English language. The treaty generally follows the UN Model (2001). The maximum rates of withholding tax are: – 10% on dividends; –   10% on interest; and –   10% on royalties. Deviations from the UN Model (2001) include that: – a services permanent establishment(PE) exists only if the activities are carried out for a period exceeding in the aggregate 183 days in any 12-month period (article 5(3)(b)); –   a force of attraction clause applies subject to the...