South African Ruling on MFN Withholding Exemption for Preference Share Dividends Paid to Sweden

On 28 June 2017, the South African Revenue Service published Binding Private Ruling (BPR) 276 – Dividends tax and the most favoured nation clause in a tax treaty. The ruling concerns the payment of dividends that may accrue in respect of preference shares in a South African company wholly-owned by a Swedish Company and whether the MFN clause under the 1995 South Africa-Sweden tax treaty as amended by the 2010 protocol applies.

In line with a previous ruling on general dividend payments to S…