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South Africa Publishes Synthesized Texts of Tax Treaties with Mauritius, Norway, Oman, Poland, Qatar, and Saudi Arabia as Impacted by the BEPS MLI — Orbitax Tax News & Alerts

The South African Revenue Service (SARS) has published the synthesized texts of the tax treaties with Mauritius, Norway, Oman, Poland, Qatar, and Saudi Arabia as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 2013 South Africa-Mauritius tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 July 2023.

The MLI applies for the 1996 South Africa-Norway tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 July 2023.

The MLI applies for the 2002 South Africa-Oman tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 July 2023.

The MLI applies for the 1993 South Africa-Poland tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 July 2023.

The MLI applies for the 2015 South Africa-Qatar tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 July 2023.

The MLI applies for the 2007 South Africa-Saudi Arabia tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 July 2023.

Click the following link for the SARS Multilateral Instrument (MLI) webpage, which includes the synthesized texts of South Africa's tax treaties.