Christos Paraskevas2019-04-29T23:10:11+01:00On 1 April 2015 Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since 8 December 1998.
The Protocol amends the 1997 DTA in three areas, namely the definition of residence, withholding taxes on dividends and exchange of information. Importantly, it does not change the existing, highly beneficial, arrangements regarding taxation of capital gains.
Residence
The Protocol aligns the definition of "resident of a Contracting State" with the...