Hong Kong – South Africa: Tax Treaty Enters Into Force

The Income Tax Treaty between Hong Kong and South Africa entered into force on 3 November 2015.

The provisions of the Treaty will become effective on 1 April 2016 in Hong Kong and on 1 January 2016 in South Africa.

The Treaty was signed in October 2014.

In accordance with the treaty, the following withholding taxes will apply:

Dividends:

• 5% if the beneficial owner is a company which holds directly at least 10% of the capital of the company paying the dividends.
• 10% in all other cases.

Interest: 10%.

Royalties: 5%.