uk limited co deemed resident in south africa

could a uk limited co deemed resident in south africa be required to deduct SA WHT?

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could a uk incorporated limited company deemed resident in south africa due to sole director physical presence  for more than 183 days be required to deduct SA WHT from dividend payments made whilst the director and company were resident in SA?

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By Accountant A
17th Oct 2018 17:14

Presumably the answer is, subject to the facts, yes.

You would need to consider what the DTA between the UK and S Africa has to say, as well as local S African tax law.

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By chicken farmer
17th Oct 2018 17:38

What does the company do and where does it do it? You will need to consider this when deciding the company's residence under the DTA (Remember if incorporated since 1988 the company will automatically be UK resident under domestic law)

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By nick farrow
17th Oct 2018 17:49

great thanks AA & Chicken farmer - under the DTA and local law the answer does appear to be yes

the company is just a standard PSC providing producing services within film & TV industry

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