South Africa: Tax reform with implications for foreigners
From 1 April 2012, a dividends tax (DT) replaced the Secondary Tax on Companies (STC). The DT rate is 15% on receipt of dividends, whereas STC was imposed on companies (at a rate of 10%) on the declaration of dividends.
By contrast with the STC, the DT allows reduced rates for foreign residents, in instance where Double Taxation Agreement (DTA) exists between South Africa and their country of residence. This normally requires the foreign beneficial owner to be a company and to hold between 10% and 25% of the share capital of the South African company declaring the dividend.
Any Evidence-Based Deliberation:
|Is there anything in the public record to suggest that evidence of the effectiveness of the proposed measure was considered during official deliberations?|
|Is there any evidence that alternatives to the proposed measure were considered?|
|Is there anything in the public record that suggests that empirical evidence informed the comparison across the alternatives available to government?|
|Was such evidence identified?|
|Is such evidence publicly available?|
|Did the official decision-maker in question provide an explanation as to why a chosen measure was favoured over alternatives?|
|Is there any evidence to suggest that potentially affected trading partners were consulted before the measures were taken?|
|Is there any evidence that safeguards have been put in place to ensure that implementation of the initiative is transparent and non-discriminatory?|
|Did the government state its intention to review the measure within one year of implementation?|
Date of inception: 1 Apr 2012
GTA Evaluation: Green
UNCTAD /OECD Seventh Report on G20 Investment measures