International Tax
There is a number of Double Taxation Agreements (DTA) in existence between South Africa and various countries that provide for relief in respect of royalties and know-how withholding taxes. There is no withholding tax on dividends or interest flowing out of South Africa.
The withholding tax on royalties paid from South Africa is as follows.
ROYALTIES NOTES
NON-TREATY COUNTRIES 12
TREATY COUNTRIES
ALGERIA 10
AUSTRALIA 10
AUSTRIA 0
BELGIUM 0
BOTSWANA 12 (9)
CANADA 10 (2)
CROATIA 5
CYPRUS 0
CZECH REPUBLIC 10
DENMARK 0
EGYPT 12 (9)
FINLAND 0
FRANCE 12 (1)
GERMANY 12 (1)
GRENADA 12
HUNGARY 0
INDIA 10
INDONESIA 10
IRAN 10
IRELAND 0
ISRAEL 12 (1) (3)
ITALY 6
JAPAN 10
KOREA 10
LESOTHO 10
LUXEMBOURG 0
MALAWI 12 (1)
MALTA 10
MAURITIUS 0
NAMIBIA 10
NETHERLANDS 0
NORWAY 0
PAKISTAN 10
PEOPLES REPUBLIC OF CHINA 0 (9)
POLAND 10
ROMANIA 12 (9)
RUSSIAN FEDERATION 0
SEYCHELLES 12
SIERRA LEONE 12
SINGAPORE 5
SLOVAK REPUBLIC 10
SWAZILAND 12 (1)
SWEDEN 12 (1)
SWITZERLAND 0
THAILAND 12 (9)
TUNISIA 10
UNITED KINGDOM 12 (1)
USA 0
ZAMBIA 12 (1)
ZIMBABWE 12 (1)
Part of the DTA with the United Kingdom
NOTES
1) If the royalty is subject to tax in the recipients country of residence there is no withholding tax
2) Rate reduced to 6 in respect of copyright royalties for use of computer software or for use of any patent or any industrial commercial or scientific information. Reduced rate does not apply to royalties in respect of films or videos or other means of reproduction for use in television broadcasting nor does it apply to information in connection with rental franchise agreements.
3) As per 1 note with the exception of the use of cinematograph or television film where withholding tax of 15 of the company tax rate (i.e. 525 ) applies
4) With the exception of Austria Canada Croatia Czech Republic Denmark Finland India Ireland Japan Korea Malta Norway Singapore UK and USA there is no relief granted in respect of STC.