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.