The pending protocol to the 2008 income and capital tax treaty between Germany and South Africa was signed on 6 March 2024. The protocol is the first to amend the treaty, which is not yet in force, and includes the following main changes:
- The preamble is replaced in line with BEPS standards;
- Article 2 (Taxes Covered) is amended in respect of South Africa, including that the treaty covers South African normal tax, withholding tax on royalties, dividends tax, withholding tax on interest, and t…