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