As previously reported, the 2021 protocol to the 2004 income tax treaty between Kuwait and South Africa entered into force on 2 October 2024, which includes the replacement of Article 10 (Dividends) with retroactive effect from 1 April 2012. Article 10 originally provided a withholding tax exemption. The new Article 10 as per the protocol provides for a 5% withholding tax rate on dividends if the beneficial owner is a company directly holding at least 10% of the paying company's capital, oth…