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HMRC internal manual

Double Taxation Relief Manual

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

United Kingdom interest arising after 5 April 2003 and South African interest arising after 31 December 2002

The agreement provides that interest paid to a resident of the other State who is the beneficial owner of the interest shall be taxable only in the State of residence.

Interest arising in earlier periods

Any problems arising in earlier periods relating to the tax on interest can be referred to the Tax Treaty Team.