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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

UK interest paid to a resident of South Africa

From 6 April 2003: Article 11 of the 2002 Convention

Full relief from UK tax is available on UK interest paid to a resident of South Africawho is the beneficial owner of the interest.

Before 6 April 2003: Article 10 of the 1969 Convention

UK interest paid before 6 April 2003 to a resident of South Africa who is thebeneficial owner of the interest is taxable in the UK at 10%, provided that the interestis subject to tax in South Africa.