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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: South Africa: Agreement

The comprehensive agreement (SI 2002/3138) entered into force on 17 December 2002 and has effect:

a) In the United Kingdom for corporation tax from 1 April 2003 and for income tax and capital gains tax from 6 April 2003.

b) In South Africa from 1 January 2003.

A protocol amending the 2002 agreement (SI 2011/2441) entered into force on 13 October 2011. It amends the dividend and exchange of information articles and introduces an article on assistance in collection. The protocol has effect in respect of exchange of information and assistance in collection for requests made on or after the date of entry into force. The provisions relating to dividends entered into force on 1 April 2012, the date on which South Africa introduced a system of taxation at shareholder level for dividends declared.

If using the HMRC Intranet, the agreement and protocol can be viewed through the “New treaties/protocols in force” link on the sidebar. On the HMRC web-site, searching for “Treaties in force South Africa” will provide a link to the agreement.

The text of the Tax Treaty can be found via