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Withholding tax on cross-border interest introduced

09 January 2011

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Approved Changes

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South Africa

A new Part IA under Chapter I of the Income Tax Act, 1962 has been introduced. It provides for a final withholding tax of 10% to be imposed on interest paid to non-residents. Currently, interest paid to non-residents is exempt from tax. Except if the interest is attributable to a permanent establishment of a non-resident in South Africa, the exemption on cross-border interest will continue to apply on interest from: -   bonds issued by any sphere of Government; -   debt listed on the Johannesburg Stock Exchange (JSE) or a foreign stock exchange; -   any debt owed by...