South Africa-Germany treaty and the secondary tax on companies

Journal
Mazansky, E.
Bulletin for International Taxation 2008 (Volume 62), No. 10
PriceUSD 45

In a recent decision involving Volkswagen of South Africa, the High Court of South Africa held that the South African secondary tax on companies is not a tax on dividends for purposes of the South Africa-Germany treaty. This article discusses the High Court's decision.