This contribution represents the South African chapter to this comparative work. The book as a whole provides:"Understanding the major trends in tax policy around the world is of great relevance not only for researchers, but also for tax policy makers, government officials and tax practitioners...

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...

This paper forms part of a series providing the opportunity for comparative analysis of the tax treaty case law of the BRICS. The comparative analysis will assist to establish whether or not there are similarities, convergences or disparities in interpretation of international tax treaties by...

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...