The South African Revenue Service (SARS) has published a draft interpretation note for public comment on the withholding tax on royalties. South Africa currently imposes withholding tax on royalties paid to foreign persons at the rate of 15%. The withholding tax rules are contained in sections 49A to 49H of the Income Tax Act, which replaced the prior rules under Section 35 of the Act effective 1 July 2013. The draft interpretation covers all aspects of the application of the rules, including…