More details have become available with respect to the new Netherlands-South Africa tax treaty and protocol on income and capital of 10 October 2005.

The withholding tax on dividends is 0% if the receiving company owns directly at least 10% of the capital of the distributing company. The protocol to the treaty contains a provision allowing South Africa to levy a 5% branch profit tax (but not if a permanent establishment becomes subject to the secondary tax on companies).

Deviations from the OECD Model include:

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Art. 4 Residents: the treaty also applies to exemp…