Details of the first-time income tax treaty and protocol between South Africa and Malaysia, signed on 26 July 2005, have become available. The treaty was concluded in the English and Malay languages, each text having equal authenticity. In the case of divergence, however, the English text prevails. The treaty generally follows the OECD Model Convention (2005). The maximum rates of withholding tax are: -   10% on dividends in general and 5% where the beneficial owner is a company holding at least 25% of the capital of the paying company; -   10% on interest, subject to exceptions in respect...