Cyprus-South Africa Double Tax Treaty Amendments - January 2016

On 1 April 2015 the Republic of Cyprus and the Republic of South Africa signed a Protocol amending the existing Double Taxation Agreement (“DTA”) between the two countries, which was signed in 1997 and entered into force in December 1998. Both countries have completed the ratification process (Cyprus in May and South Africa in December 2015) with the Protocol being enforced with retrospective effect as from 18 September 2015. The amended DTA maintains the highly beneficial provision on capital gains taxation.

The three main areas amended by the Protocol are:

  • the definition of residence;
  • withholding taxes on dividends; and
  • exchange of information.


For more information, please contact our Cyprus office.