South Africa
A. Progress in the implementation of the minimum standard
South Africa has 79 tax agreements in force as reported in its response to the Peer Review questionnaire. None of those agreements comply with the minimum standard.
South Africa signed the MLI in 2017 and deposited its instrument of ratification on 30 September 2022. The MLI enters into force for South Africa on 1 January 2023. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
South Africa has not listed its agreements with Germany, Grenada, Sierra Leone and Zambia under the MLI. These agreements will therefore not, at this stage, be modified by the MLI.
South Africa indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in its agreements with Germany, Malawi* and Zambia.
South Africa is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1
B. Conclusion
South Africa has developed a plan for the implementation of the minimum standard in its agreements with Grenada and Sierra Leone. South Africa indicated in its response to the Peer Review questionnaire that bilateral negotiations would be pursued with respect to those agreements.
Note
← 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).