DTA with South Africa
Income from immovable property: may be taxed in Country State where immovable property situated.
Business profits: taxed in Country State where enterprise based. Unless enterprise has permanent establishment in other Country State where profits may be taxed.
Dividends: shall be taxable only in Country State where beneficial owner is resident, provided recipient is beneficial owner of dividend.
Interest: shall be taxable only in Country State where recipient is resident, as long as recipient is beneficial owner of interest.
Royalties: shall be taxable only in Country State where recipient is resident, as long as recipient is beneficial owner of interest.
Capital gains: may be taxed in Country State where immovable property situated.
South Africa
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