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HMRC internal manual

International Manual

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

UK dividends paid to a resident of South Africa - portfolio investor

From 6 April 2003: Article 10 of the 2002 Convention

There is no provision for payment of tax credit on UK dividends.

Before 6 April 2003: Article 9 of the 1969 Convention

There is a ‘subject to tax’ condition for relief on UK company dividends.