Details of the income and capital tax treaty and protocol betweenGermany and South Afica, signed on 9 September 2008, have become available. The treaty was concluded in the German and English languages, each text having equal authenticity. The treaty generally follows the OECD Model Convention.
The maximum rates of withholding tax are 15% on dividends in general, reduced to 5% if the beneficial owner is a company (does not apply to partnerships) holding directly…