South Africa

South Africa has 79 tax agreements in force, as reported in its response to the Peer Review questionnaire.

South Africa signed the MLI in 2017 and has not listed its agreements with Germany, Grenada, Sierra Leone and Zambia. It indicated in its response to the Peer Review questionnaire that bilateral negotiations would be used with respect to its agreements with Brazil, Germany and Zambia. These agreements will therefore not, at this stage, be modified by the MLI.

South Africa is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1

The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.

South Africa’s listed agreements under the MLI will start to be compliant after South Africa’ ratification of the MLI. South Africa is encouraged to ratify the MLI as soon as possible.

As mentioned above, South Africa has not listed its agreements with Grenada and Sierra Leone under the MLI. Listing the agreements under the MLI or entering into bilateral renegotiations to implement the minimum standard would ensure that the minimum standard could be implemented in those non-covered agreements.


← 1. For its agreements listed under the MLI, South Africa is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI).

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