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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 22

Elimination of Double Taxation

Double taxation shall be eliminated as follows:

  • (a) in the case of Slovakia, Slovakia, when imposing taxes on its residents, may include in the tax base upon which such taxes are imposed the items of income which according to the provisions of this Convention may also be taxed in South Africa, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in South Africa. Such deduction shall not, however, exceed that part of the Slovak tax, as computed before the deduction is given, which is appropriate to the income which, in accordance with the provisions of the Convention, may be taxed in South Africa.
  • (b) in the case of South Africa, Slovak tax paid by residents of South Africa in respect of income taxable in Slovakia, in accordance with the provisions of this Convention, shall be deducted from the taxes due according to South African fiscal law. Such deduction shall not, however, exceed an amount which bears to the total South African tax payable the same ratio as the income concerned bears to the total income.