New Rules for Tax on Dividends (Domestic and Foreign) and Other Company Distributions

Journal
South Africa
Bulletin for International Taxation 2012 (Volume 66), No. 3
This article addresses recent significant changes in the way tax is imposed on both domestic and foreign dividends, as well as the treatment of a return of capital. It also examines whether or not, in certain cases, the right of South Africa to impose the tax under tax treaties could be disputed by non-resident shareholders.