Double Taxation Agreements

Double Taxation Agreements


ATAF Consultative Conference on new rules of the Global Tax Agenda

On 18 and 19 March 2014, the Council of the African Tax Administration Forum (ATAF) met with the Heads of African Tax Administrations and Ministries of Finance from 29 African countries in order to deliberate on the New Rules of the Global Tax Agenda.

Sweden Protocol effective from 18 March 2012

The main amendment relates to taxation of dividends and related relief (article 10(2)). The maximum tax is set at 10% and a rate of 5% will apply if the beneficial owner is a company (other than a partnership) which holds at least 10 per cent of the capital of the company paying the dividends.

Malaysia Protocol entry into force on 6 March 2012

The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement

Ireland Protocol entry into force on 10 February 2012

"A Common Contractual Fund established in Ireland shall not be regarded as a resident of Ireland and shall be treated as fiscally transparent for the purposes of granting tax treaty benefits”.

South Africa renegotiates double tax agreement with Mauritius

South Africa and Mauritius have concluded a new double tax agreement ("DTA”) on 17 May 2013. Changes to the existing DTA includes changes to the treaty tie-breaker rules as well as the requirements for companies to be "effectively managed” in Mauritius. Below you will find summaries of some of the key features of the new treaty.

African treaty to curb tax fraud and evasion

Member states of the African Tax Administration Forum (‘ATAF’) will be meeting in Pretoria this week (25 – 27 July 2012) to facilitate the exchange of information among African tax administrations with a view to combating fraud and tax evasion within Africa.

Seychelles Protocol

This tax alert contains the amendments brought about by the Protocol entered in between the RSA and Seychelles.

Amendments to Double taxation treaties (Protocols published in the Gazette)

This protocol was published on 23 April 2012, but as agreed in paragraph 1 of Article III of the Protocol, the date of entry into force is fixed as 18 March 2012

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