🇿🇦 South Africa — 🇬🇧 United Kingdom

Tax Treaty / Double Tax Avoidance Agreement detail

<300-400 words: signed 4 July 2002, in force 17 December 2002; significant for the ~250,000 South African expatriates in UK and the large UK retiree community in SA; both Commonwealth members; dividend WHT 5% for substantial holdings (10%+), 15% otherwise; 0% interest WHT, 0% royalty WHT (favourable compared to OECD model); MLI signed by both — SA ratified; arbitration via MAP; SA introduced exit charge on tax emigration (Section 9H Income Tax Act 1962) which intersects with the treaty's residence article; UK Statutory Residence Test (SRT) interaction; particular note that SA Reserve Bank exchange control rules separate from tax treaty obligations; no bilateral totalization agreement — South African UIF (Unemployment Insurance) and UK National Insurance operate independently; CRS participation by both>