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Treaty between Switzerland and South Africa – details

27 July 2008

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Approved Changes

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Switzerland-South Africa

Details of the new income tax treaty and protocol between Switzerland and South Africa, signed on 8 May 2007, have become available. The treaty replaces the tax treaty signed on 3 July 1967. The treaty was concluded in the French and English languages, each text having equal authenticity. The treaty generally follows the OECD Model Convention; however, some provisions are based on the UN Model Convention. The maximum rates of withholding tax are: 15% on dividends in general, and 5% on dividends in case of shareholdings of at least 20% in the share capital of another corporation; 5% on interest;...