This paper focuses on the agreements and treaties entered into for the relief of income tax, death duties and double taxation of air and sea transport in the period 1932 to 1990. The paper excludes from its scope customs (for example, the Agreement between the Union of South Africa and Southern...

This article addresses, in part, the use of the OECD Commentaries with respect to the interpretation of bilateral tax treaties. However, the article has as its focus those instances in which a tax treaty or protocol to a tax treaty, in the main, directly reference the OECD Commentaries as an...

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...

This article considers double non-taxation in relation to the New Zealand–South Africa tax treaty. It addresses the application of South African withholding tax to a New Zealand resident disposing of immovable property in South Africa and concludes with some recommendations as to how to...