Taxation of non-residents in South Africa

This research tests the effectiveness of withholding taxes imposed by the South African tax authorities with respect to amounts paid from a South African source to a non-resident in respect of interest, royalties and foreign entertainers and sportspersons. The first research objective discusses the alignment of the meaning of words and phrases in both the domestic law of South Africa and Double Tax Agreements (DTA). The second issue outlines whether the DTA supports the domestic law through the waiving of tax claims in favour of the country of source. In the last instance the attribution of income is discussed.