Model Tax Convention

August 14, 2025 Robyn van der MerweIncome Tax, Income Tax Act, Model Tax Convention

Withholding tax on royalties—SARS Interpretation Note 116, part 3

Source information: SARS INTERPRETATION NOTE 116, dated 23 April 2021, and the INCOME TAX ACT 58 OF 1962, SECTIONS 49A to 49H The 40-page SARS Note provides guidance on the […]

April 18, 2024April 18, 2024 Robyn van der MerweIncome Tax, Income Tax Act, Model Tax Convention

RESIDENT – PLACE OF EFFECTIVE MANAGEMENT

– INCOME TAX ACT 58 OF 1962 SECTION 1(1) A “place of effective management”, in determining the tax residence of a company, is only one of the considerations under the […]

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16 January 2026 – Taxation of Foreigners Working in South Africa, Part 6
AARTO’S POINTS DEMERIT SYSTEM— ROAD TRAFFIC INFRINGEMENTS
Accounting Officers and Registered NPO’s
Addressing the Tax Challenge Arising from the Digitalisation of the Economy – OECD and International Tax Legislation
Administrative Penalties for Corporate Income Tax (CIT)
Administrative penalties for corporate income tax (CIT) to be imposed
Amendments to regulations on the domestic reverse charge relating to valuable metal
Annual carbon tax accounts and payments are now due by 29 July 2021
Annual Tax Returns
Application of proviso to Section 8EA(3) of the Income Tax Act
Assessed losses under the Income Tax Act
Attribution of nett income to a Public Benefit Organisation
Bargaining Councils, what are they?
Basic Principles for S18A Approved Tax Exempt Institutions
Being Audited or Selected for Verification by SARS
BINDING PRIVATE RULING BPR 425 of 31 March 2026 – REHABILITATION OF MINING PROPERTY
Block exemption regulations for small, micro and medium-sized businesses
Bursaries awarded by a Resident Company and the Income Tax Consequences
Business Rescue
Cancellation of VAT registration (deregistration)
Capital Gains Tax
Capital Gains Tax for Companies – part 1
Capital Gains Tax for Companies – part 2
Capital Gains Tax for Companies – part 3
Carbon Tax
Carbon tax rate increase
Carbon Tax update – September 2020
CARF – Crypto Asset Reporting Framework – Business Requirement Framework
CEASE TO BE A RESIDENT AND EXPIRY OF VISA
Ceasing to be an SA Tax Resident
Clarifying the interaction between the Employment Tax Incentive and Special Economic Zone provisions
Commission earnings and taxation
Companies and taxation in South Africa
Company Tax Return Amendments
Conduct of Financial Institutions Bill – second draft available and the effect on Pension/Retirement Funds
Construction Industry Development Board (CIDB)
Contributed Tax Capital and Preference Shares
Contributed Tax Capital and Preference Shares
Corporate Income Tax Rates in South Africa
Corporate Income Tax Returns
Corporate Tax Statistics
Corporate Taxes
Cryptocurrencies and tax
Customs Duty and VAT Implications on Imported Goods
Debt reduction provisions of the Income Tax Act and Taxation Laws Amendment Act
Declaration of a crypto asset as a financial product under the Financial Advisory and Intermediary Services Act
DEDUCTIBILITY OF MINING REHABILITATION INSURANCE PREMIUMS
Deduction for Photovoltaic Solar Energy Plants
Default Regulations for Retirement Funds
Deferral of payment arrangements with SARS
Defining “Goodwill” and it’s tax treatment
Definition of “Associated Enterprises” – Section 31 of the Income Tax Act
Deregistration of Tax Types – part 1 of 2
Deregistration of Tax Types – part 2 of 2
Determination of taxable income derived from farming
Developing a Multilateral Instrument to Modify Bilateral Tax Treaties
Diesel Refund for Food Manufacturers – Registration
Diesel Refund System
Different types of shares; ordinary versus preference shares
Different types of taxes
Directors vs Shareholders
Disposal of shares subsequent to a property development arrangement.
Dispute Resolution Process – SARS, the Tax Board and the Tax Courts
DISQUALIFICATION AS A QUALIFYING COMPANY UNDER SECTION 12R(4)(b)
Dividends Tax
Dividends tax: proposed amendments to the taxation of manufactured dividends
Donations made to Public Benefit Organisations (PBOs)
Donations Tax
Donations tax implications of subscribing for shares at a discount
Donations tax implications on the issue of shares at nominal value to enhance B-BBEE credentials
Double Tax
Draft amendments to rules for the implementation of tobacco products related excise duties on nicotine and nicotine-substitute solutions in vaping products
Draft guide to the Employment Tax Incentive
Draft Income Tax Amendment Bill – Commentary
Earnings thresholds, Income Tax thresholds and Minimum Wage updates
Economic Terms and Tax Concepts — Fiscal Drag causing higher tax rates
Employee Allowances for the 2023 Tax Year
Employees’ tax – Personal Service Providers and Labour Brokers
Employees’ tax (PAYE) on your pension or annuity
Employees’ tax in respect of an independent contractor
Employment Tax Incentive
Employment Tax Incentive Term Extended
Employment Tax Incentive (ETI), Corporate Income Tax (CIT) and others
Employment Tax Incentive Part 2
Employment tax incentives – students and the definition of employees
Estate Duty – part 1
Estate Duty – part 3
Estate Duty – part 2
Estates
Estates – ESTATE DUTY IMPLICATIONS ON KEY-MAN POLICIES
Excise Tax
Exclusion of certain companies and shares from a “GROUP OF COMPANIES” as defined in Section 41(1) of the Income Tax Act
Expat tax
Explanatory Memorandum on the Taxation Laws Amendment Bill of 2021 – CARBON TAX and RENEWABLE ENERGY
Export incentives – part 1
Export incentives – part 2
February 2019 Budget Speech Summary
Financial aid during the COVID-19 crisis – Unemployment Insurance Fund
Financial fallout from the COVID-19 pandemic
Foreign Employment Income Tax
Fringe benefits and tax
Game Farming and the Income Tax Act
Global Minimum Tax – GloBE Information Return (GIR) XML File Submission
Global Minimum Tax Act
Goodwill – Capital Gains Tax and Accounting
Government Employees Pension Fund and Child Pension
Guide for employers in respect of allowances (2024 tax year)
Guide for employers in respect of fringe benefits – 2025 update
Guide for employers in respect of fringe benefits – 2025 update, article five – INSURANCE POLICIES, EMPLOYEE’S DEBT, MEDICAL SCHEME CONTRIBUTIONS, AND MEDICAL COSTS
Guide for employers in respect of fringe benefits – 2025 update, article three – FREE OR CHEAP SERVICES, INTEREST, AND DEBT
Guide on the Determination of Medical Tax Credits – June 2026 update, SARS
Guide to Advance Tax Rulings, part 1
High wealth individuals and SARS disclosure
Home Office expenses, deductions and tax
How is the base fuel price calculated?
Hybrid Equity Interest on Third-Party Shares
IFRS and IFRS 3 – Business Combinations
Income Tax and Medical Tax Credits for the Individual
Income Tax and Medical Tax Credits for the Individual
Income Tax and the Individual
Income tax return for Trusts – part 1
Income tax return for Trusts—part 2
INDIVIDUAL ITR12 RETURN FOR DECEASED AND INSOLVENT ESTATES
Inheritance tax explained
Interest deductibility in South Africa
Interest-free shareholder loans, interest-bearing loans and loans to Trusts
Interpretation Note for public comment: Understatement penalty and meaning of “maximum tax rate applicable to the taxpayer”
Key changes in the Government’s 2026-2027 budget – Income Tax for Companies
Key changes in the Government’s 2026-2027 budget – Income Tax for Individuals and Trusts
Know the difference – Accounting terminology 101
Know your terminology
Know Your Terminology – Accountant vs Auditor
Know your terminology – Taxation
Leasehold improvement allowance and Section 11(h) of the Income Tax Act
Liquidation
List of Qualifying Physical Impairment or Disability Expenditure
Mining and Petroleum Royalties and Taxation
Mining rehabilitation of a Company or Trust: Deductibility of amounts paid and compliance with Section 37A of the Income Tax Act – part 1 of 2
Moonlighting – employers and employees
New Air Passenger Tax System
New filing requirements for insolvent taxpayers
Non-compliance with laws and regulations – NOCLAR
Non-Executive Directors and VAT and PAYE
Non-profit organisation-related law and benefits in South Africa – article 1 of 2
Non-profit organisation-related law and benefits in South Africa – article 2 of 2
Notional VAT
NPOs, corrupt activities and the Financial Action Task Force (FATF)
NPOs, corrupt activities and the Financial Action Task Force (FATF)
PAYE-AS-YOU-EARN (PAYE) Penalties
PAYE, CCMA, Labour Court Awards and the Income Tax Act 58 of 1962
Payroll Services
Photovoltaic Solar Energy Plants
Physical Impairment or Disability Expenditure
PRE-TRADE EXPENDITURE AND LOSSES
Prohibition of deductions in respect of certain intellectual property – part 1
Promissory Notes and Taxation
Provident Funds
Public Benefit Organisations: Capital Gains Tax – part 1
Public Benefit Organisations: Capital Gains Tax – part 2
Public Interest Score
Public Schools and Income Tax
Publication of multilateral convention to implement the tax-treaty related measures to prevent base erosion and profit shifting (BEPS MLI)
Publication of the draft amendments to the regulations on the domestic reverse charge relating to valuable metal
PURCHASE OF DIFFERENT TYPES OF ANNUITIES AT RETIREMENT
Rand Mutual Assurance Fund – earnings reporting for compensation and assessment purposes
Re-enforcing Tax Compliance
Recreational Clubs and tax
Registering as a Trust
Rendering of transport services by an employer
Renewable Energy Incentives
Residence Based Taxation and Foreign Employment
RESIDENT – PLACE OF EFFECTIVE MANAGEMENT
RETURNS TO BE SUBMITTED BY A PERSON IN TERMS OF SECTION 25 OF THE TAX ADMINISTRATION ACT, 2011 (ACT NO. 28 OF 2011)
Rules for the taxation of interest payable by SARS under Section 7E of the Income Tax Act
SARS and Tax Assessment Prescriptions
SARS and Tax Assessment Prescriptions – 2026 Update
SARS Guide for Tax Rates/Duties/Levies (Issue 16)
SARS GUIDE ON THE SOLAR ENERGY TAX CREDIT PROVIDED
SARS VAT Rulings Process Guide
SARS’ Official Functions
Savings vs Investments
Section 11D of the Income Tax Act – Research & Development (R&D) tax incentive’s proposed amendments
Section 13 of the Income Tax Act
Section 13 of the Income Tax Act No. 58 of 1962 – property investment and tax relief
Section 18A – Audit Certificates, Part 1
Section 18A – Audit Certificates, Part 2
Section 23H of the Income Tax Act, No 58 of 1962 – deductions claimed for prepaid expenditure
Section 25BB of the Income Tax Act – Taxation of REIT’s – “Real Estate Investment Trust”
Sections 225 and 360 of the NOCLAR provisions – Obligations for Professional Accountants
SECURITIES TRANSFER TAX
SECURITIES TRANSFER TAX IMPLICATIONS ON THE RE-USE OF COLLATERAL
SEZ’s or Special Economic Zones
Shareholder Liability For Tax Debts Of A Company
Small businesses and taxation
Solar panel tax incentive for individuals
Sole Proprietorship and Tax
Some changes made to the Taxation Laws Amendment Bill, 2020
Standard Turnover-based Method of Apportionment – Draft Binding Ruling for comment
Standard Turnover-based Method of Apportionment – Draft Binding Ruling for comment – part 2 – Exclusions
Starting up a business in South Africa
Submission of Annual Financial Statements
Submission of Annual Personal Income Tax Returns
Submission of Annual Personal Income Tax Returns and your obligations
Submission of production, costing and trade statistics to Statistics South Africa (STATSSA)
Supplier and Enterprise Development contributions and Taxation
Tax and retirement
Tax Avoidance and Income Tax Act
Tax Avoidance vs Tax Evasion
Tax Avoidance vs Tax Evasion – Infographic
Tax Compliance Status and international transfers for a non-resident
Tax consequences of impermissible tax avoidance
Tax consequences of impermissible tax avoidance
Tax Consequences of the Termination of an En Commandite Partnership
Tax Deductions (PAYE) on your Pension or Annuity
Tax Directives
Tax exemption for foreign employment income
Tax Exemption Guide for Recreational Clubs – Issue 5 (2025)
Tax Exemption Guide for Recreational Clubs – Issue 5 (2025), part 2 – Other applicable tax liabilities
Tax Exemption Guide for Recreational Clubs – Issue 5 (2025), part 3 – Administrative provisions of the Tax Administration Act
Tax Exemption Guide for Recreational Clubs – Issue 5 (2025), part 4 – Record-keeping and Income Tax Returns provisions of the Tax Administration Act
Tax filing season starts on 01 July
Tax Free Investments
Tax Guide for Share Owners
Tax Guide for Small Businesses
Tax implications arising from the conversion of par value shares to no par value shares
Tax Implications for Resident Beneficiaries of a Foreign Pension Trust
Tax Incentives and Renewable Energy
Tax Incentives and their expiry date
Tax Incentives for Research and Development
Tax Obligations of Home Owners Associations (HOAs)
Tax on Foreign Earnings
TAX ON INHERITANCE, DONATIONS AND A DECEASED ESTATE
Tax refunds from SARS
Tax relief and the R500 billion breakdown
Tax returns and the 3-year limitation period of the Tax Administration Act
TAX RETURNS TO BE SUBMITTED BY A PERSON IN TERMS OF SECTION 25 OF THE TAX ADMINISTRATION ACT
Tax treatment of customer loyalty programmes
Tax treatment of doubtful debts and debt write-off
Tax treatment of spouses married in community of property
Tax-based incentives offered by Government to businesses operating in South Africa
Tax-based incentives offered by Government to businesses operating in South Africa(part2)
Taxation in South Africa
Taxation Laws Amendment Bill, 2020 and Tax Administration Laws Amendment Bill, 2020 now promulgated as law in January 2021
Taxation of Divorce Settlements
Taxation of Farming Operations
Taxation of Foreigners Working in South Africa
Taxation of Foreigners Working in South Africa, Part 2
Taxation of Foreigners Working in South Africa, Part 3
Taxation of Foreigners Working in South Africa, Part 4 — Benefits
Taxation of Foreigners Working in South Africa, Part 5
Taxation of Foreigners Working in South Africa, Part 7 – income, deductions, and allowances
Taxation of Foreigners Working in South Africa, Part 8—Capital Gains Tax, Tax on Foreign Entertainers and Sportspersons, and Provisional Tax
TAXATION OF REIT’s
TAXATION OF THE RECEIPT OF DEPOSITS
Taxation of the receipts of deposits – Part 2
Taxpayers and retention of records as per the Tax Administration and Companies Acts
Temporary application of new dwellings for exempt supplies simultaneously held by developers for taxable purposes
The 2020 Budget, tax matters, SAA, Eskom and a lower government employee wage bill
The Carbon Tax Act
The Compensation Fund and Rand Mutual Assurance Fund
The Diesel Rebate Explained
The DTI’s Special Economic Zones Tax Incentive Guide
The Financial Sector Conduct Authority’s proposal to make crypto assets a financial product
The Five Transfer Pricing Methods
The FSB and FSCA
The Impact of the Corona-Virus on the nationwide lockdown in South Africa
The Importance of Producer Price Inflation Statistics
The International Corporate Tax Problem – Base erosion and profit shifting (BEPS)
The meaning of “SIMILAR FINANCE CHARGES” – an interpretation from SARS
The National Credit Amendment Bill
The Prime Lending Rate of the Reserve Bank
The Promotion of Access to Information Act, 2000 (Act 2 of 2000) – requests for information and lodging of complaints with the Regulator
The SARS Voluntary Disclosure Programme (VDP)
The similarities and differences between non-profit (NPO) and for-profit organisations and the legal requirements for a NPO
The similarities and differences between non-profit (NPO) and for-profit organisations and the legal requirements for a NPO
The tax effects of your crypto assets
The two types of UIF claims during the COVID-19 lockdown explained
The Two-Pot Retirement System
The Unemployment Insurance Fund (UIF)
The Value-Added Tax Treatment of Debt Collection
Things to know about Section 18A donations
Trademarks,logos,slogans, intellectual property and the registration thereof
Transfer Pricing Methods – The Cost Plus Method
Transparency and Beneficial Ownership – Legal Entities and Legal Arrangements
Trusts
Trusts and taxation of the beneficiaries thereof
Turnover Tax
Turnover Tax – A quick test from SARS for individuals and companies
Types of Companies, Registration of them and financial reports and auditing
Understanding how SARS imposes admin penalties
Updates to the Taxation Laws of South Africa
Urban Development Zone Allowance
Value-added tax (VAT)
Value-Added Tax Modernisation
VALUE-ADDED TAX TREATMENT OF ROUNDING DIFFERENCE IN CASH TRANSACTIONS
VAT 404 – A SARS Guide for Vendors, version 15, and Registration for VAT
VAT on electronic services
VAT relief for importers in the time of the COVID-19 pandemic
Venture Capital Companies
Waiver of debt by an employer relating to the unwinding of a share purchase scheme
Wear-and-tear or Depreciation Allowance
What is a non-profit organisation?
Wilful conduct (misconduct) for tax related offences – proposed amendments as per 2020 Draft Taxation Laws Amendment Bill (Draft TLAB) and the 2020 Draft Tax Administration Laws Amendment Bill (Draft TALAB)
Withholding Tax on Royalties
Withholding tax on royalties
Withholding tax on royalties – part 4
Withholding Tax on Royalties (WTR)
Withholding tax on royalties—SARS Interpretation Note 116, part 3
Workmans Compensation
WSP & ATR submission
Zero-rated VAT items

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