A protocol to the 1997 income and capital tax treaty between Cyprus and South Africa entered into force on 18 September 2015. The protocol, signed 1 April 2015, is the first to amend the treaty and includes the following:
- The definition of a "resident of a Contracting State" under paragraph 1 of Article 4 (Resident) is replaced;
- Article 10 (Dividends) is replaced, with a 5% withholding tax if the beneficial owner is a company directly holding at least 10% of the paying company's capital, oth…