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The Netherlands Ministry of Foreign Affairs has stated in a press release that the Netherlands and South Africa signed a new income and capital tax treaty on 10 October 2005. Once in force, the new treaty will replace the current Netherlands-South Africa income tax treaty of 15 March 1971. The intention of the new treaty is to bring matters into line with the fiscal developments in both states. The text of the new treaty is not yet available, but the press release indicates the details summarized below regarding the new treaty.

09 November 2005|Treaty Development|Netherlands-South Africa

The maximum withholding taxes are:

…

-		15% on dividends, in general, and 0% on dividends in respect of a shareholding of 10% in the distributing company (the press release does not indicate whether the 10% refers to the capital or to the voting rights in the distributing company – in the existing treaty the threshold is 25% of the voting power);
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