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June 26, 2026

This agreement seeks to avoid double taxation. Covered taxes under Article 2 are, for the UAE: the income tax and corporation tax; for South Africa: the normal tax, the withholding tax on royalties, the dividend tax, the withholding tax on interest, and the tax on foreign entertainers and sportspersons. Withholding rates are 5% for dividends if holding ≥10% capital (10% otherwise), 10% for interest, and 10% for royalties. Domestic laws may apply to hydrocarbon income (Article 1). Per Article 22, South Africa uses the credit method and the UAE uses the exemption method.

Agreement between the Government of the REPUBLIC OF SOUTH AFRICA and the Government of the UNITED ARAB EMIRATES for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

[GTL Notes - See Protocol 1]

StatusIn Force

Signed on23 November 2015

Entered into force23 November 2016

Amended on-

Terminated on-

The Government of the Republic of South Africa and the Government of the United Arab Emirates desiring to promote and strengthen their economic relations by concluding an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, HAVE AGREED AS FOLLOWS:

Contents

Article 1 - Persons Covered

Article 2 - Taxes Covered

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

Article 6 - Income From Immovable Property

Article 7 - Business Profits

Article 8 - Shipping And Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Income From Employment

Article 15 - Directors' Fees

Article 16 - Entertainers And Sportspersons

Article 17 - Pensions And Annuities

Article 18 - Government Service

Article 19 - Professors And Teachers

Article 20 - Students And Trainees

Article 21 - Other Income

Article 22 - Elimination Of Double Taxation

Article 23 - Non-Discrimination

Article 24 - Mutual Agreement Procedure

Article 25 - Exchange Of Information

Article 26 - Members Of Diplomatic Missions And Consular Posts

Article 27 - Refunds

Article 28 - Miscellaneous Rules

Article 29 - Entry Into Force

Article 30 - Termination

Protocol

Article 1
Persons Covered

This Agreement shall apply to persons who are residents of one or both of the Contracting States.
Nothing in this Agreement shall affect the right of either Contracting State, any political subdivision, local authority or local government thereof, to apply its own laws and regulations relating to the taxation of income and profits derived from hydrocarbons situated in that State.

Article 1Persons Covered

Article 2Taxes Covered

Article 1
Persons Covered

Article 2
Taxes Covered