Status Quo of South African Tax Treaty Policy

The paper has as its purpose to derive the South African tax treaty policy from the existing treaties, the use of a former South African tax treaty model and recorded positions on the OECD Model Convention on Income and on Capital (OECD Model). As the focus is on the current position of the South African tax treaty policy, reference to the recorded positions in the 2014 version of the OECD Model will be used and reference to earlier versions is made where necessary