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HMRC internal manual

International Manual

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

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Other income paid to a resident of South Africa

From 6 April 2003: Article 20 of the 2002 Convention

Relief is available only for ‘other income’ that arises in a third country.

Before 6 April 2003: Article 20 of the 1969 Convention

There is a subject to tax condition for other income. State Pensions fall under theprovisions of this article, but no relief is available because a State Pension is notsubject to tax in South Africa.