(October 17, 2014)

On October 16, 2014, Hong Kong and South Africa signed an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (Hereafter: DTA).

The DTA caps dividend withholding taxes at 5 % (in case of direct shareholdings of at least 10%) and at 10% in all other cases. Under the DTA interest withholding taxes are capped at 10% and royalty withholding taxes are capped at 5%.

Although the DTA has been signed it has not yet entered into force. In order for the DTA to enter into force both the South African Government and the Government of Hong Kong will have to complete their respective ratification processes.

Click here to be forwarded to the text of the Agreement between the Government of the Hong Kong Special Administrative Region of the People’s Republic of China and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income as published on the website of the Hong Kong Inland Revenue Department, which will open in a new window. 

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