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Protocol on double tax treaty
A protocol amending the agreement for the avoidance of double taxation and prevention of fiscal evasion was signed between South Africa and Cyprus on the 1 April 2015. Taxand Cyprus takes a look at the new protocol.
According to the protocol, article 10 (dividends) of the double tax treaty shall be replaced with the provisions included in the protocol signed. As such, dividends paid by a company resident in one contracting state to a company resident in the other contracting state shall be taxed in the latter.
Article 26 (Exchange of Information) of the treaty will also be replaced in order to include further clarifications in relation to the exchange of information process between the two states.
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The protocol will enter into force as soon as the contracting states notify each other on the completion of the procedures required by their domestic legislation. Once the protocol enters into force it will constitute an integral part of the agreement between the two states.