South Africa (Republic of) - Anti-abuse provisions
.png){kind=logo}
| Country | South Africa (Republic of) |
| Treaty article | |
| Date signed | 10 October 2005 |
| Date entry into force | 28 December 2008 |
South Africa (Republic of)
Anti-abuse provision: Main purpose test
Article 10-8:
The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the shares or other rights in respect of which the dividend is paid to take advantage of this Article by means of that creation or assignment.
Disclaimer
The above is wording of the bilateral treaty between the Netherlands and corresponding country. Please note that the actual wording may deviate from the above wording, this may be due to for example recent amendmends or (pending) treaty negations that have not yet been included in the above wording. Before you use this information, we advise you to contact us to verify the treaty and the specifics of you case. You can reach us via email or office phone number 010-2010466.
Ton Smit
Director / Senior Consultant
Our Services
Newsletter
Don’t miss out on our regular updates on international taxation.