South African Supreme Court of Appeal Confirms Application of Protocol to a Tax Treaty to a Period before Signature Date

Journal
Mazansky, E.
South Africa
Bulletin for International Taxation 2016 (Volume 70), No. 4
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The author, in this article, considers the implications of the recent Supreme Court of Appeal of South Africa decision in Krok and Another (2015), in which the Court confirmed the retroactive application of a protocol to a tax treaty to matters that arose before the protocol was concluded.