dividend withholding tax south africa to UK

dividend withholding tax south africa to UK

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A UK company controls (own a 100%) of a South African affiliate.

The South African entity pays a dividend to the UK entity, which I believe is subject to a 5% withholding tax.

Would the UK entity be able to recover this withholding tax? 

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By richard thomas
09th Mar 2021 10:36

No, because 5% is the maximum rate under the DTA and S Africa has no reason to refund it. The UK company can claim credit for the S African tax, but only if the dividend is taxable in the UK (which seems unlikely given s 931E(2) CTA 2009).

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