South Africa

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

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).

Metadata, Legal and Rights

This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Extracts from publications may be subject to additional disclaimers, which are set out in the complete version of the publication, available at the link provided.

© OECD 2023

The use of this work, whether digital or print, is governed by the Terms and Conditions to be found at https://www.oecd.org/termsandconditions.